Discussion Paper: Digital Advertising in Financial Services

The Financial Services Consumer Panel has published its Discussion Paper today based on the findings of two pieces of exploratory research, focusing on the short-term lending and the ‘pensions-to-cash’ sectors, across social media platforms. It raised great concerns around the financial promotion of short-term lending products online especially. The Panel fears that the short-term lending industry online is not treating customers fairly by targeting their adverts to potentially the most vulnerable in society.

The Panel’s research also showed that in the online pensions-to-cash space, unregulated brokers dominate with websites lacking transparency, poor disclosures of risk warnings and adverts targeting the under 55s to access their pensions which could lead to a huge tax bill!

Panel Chair, Wanda Goldwag, says “With the outbreak of COVID-19 putting many people’s incomes in jeopardy, and throwing everyone into a mainly digital lifestyle there is increased urgency to debate the need for better consumer protection from potentially harmful financial adverts online. It is not the FCA alone who can tackle this problem, but other stakeholders, regulators and tech giants like Google and Facebook that should also be part of this important discussion.


Consumer Panel Secretariat: 020 7066 9346



  1. The Consumer Panel is a statutory body under the Financial Services Act 2012.  The Financial Services Authority originally established it in December 1998. The Panel advises the FCA on the interests and concerns of consumers.  The Panel is independent. Its views do not represent those of the FCA.  
  2. The Panel’s membership is drawn from a broad range of backgrounds with expertise including market research, law, financial services industry, financial inclusion, European Regulation, financial regulation, consumer advice, campaigning, communications, compliance and later-life issues. 
  3. In late 2019, a digital experience agency (REO) was commissioned to carry out research to understand the digital customer journey for high-cost consumer lending and consumers looking to cash in their pensions. The research comprised surveys, in-depth qualitative interviews and lab sessions with consumers who had used high-cost loans or looked to cash in their pensions in the previous six months. In February 2020, an online data analytics agency (Social Chain) was commissioned to investigate the online marketing strategies used by high-cost lenders and cash-to-pensions firms; and conduct ‘social listening’ to boost understanding about the target audiences for these two products. The work was completed in early March 2020 before the COVID-19 lockdown.
  4. While the Panel’s general policy is to publish the research it commissions, we have chosen not to publish these two studies as their content is potentially sensitive and their primary purpose was to inform the Panel’s thinking on these issues.
  5. The emphasis of the Panel's work is on activities that are regulated by the FCA, although it may also look at the impact on consumers of activities outside but related to the FCA's remit. More information about the Panel's work is available on its website: www.fs-cp.org.uk.

Wanda Goldwag (Chair)

Francis McGee

Mark Chidley

Julia Mundy

Sharon Collard

Keith Richards

Jonathan Hewitt

Natasha de Terán

Erik Porter

Dominic Lindley

Jennifer Genevieve

Julie Hunter