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This case work example describes a case we have acted upon. It is designed to help firms understand our analysis, the issues that may lead us to contact firms and the action that may result. It does not set any kind of precedent or guide about the action we may take on similar cases in the future.

Issue

The firm provided a search function for the "best" financial products available on the market. The firm's website provided details of the type of mortgage product (e.g. fixed, discounted etc) and the APR applicable at the top of the page, but consumers had to scroll down to the end of the web page to find the key risk information and potential drawbacks applicable to each product. In addition, the web page provided a direct link to the product provider's website next to the headline information which, in our view, could disincentivise consumers from obtaining full information about the product.

For this reason, our concern was that the risk warnings and key information lacked prominence, as consumers could follow the link to the application form without being prompted to read the product warnings. In our view, the risk warnings and information on the early repayment charges in particular should have been displayed in proximity to the relevant upsides, particularly as the products tied in borrowers for an extended period.

In addition, the website did not express the applicable interest rates in the required format. Where an introductory rate is stated, any fixed period must be clearly stated. The introductory rate must also be followed by the future standard variable rate (SVR) applicable, and the overall cost for comparison APR must be provided.

Action taken

In response to our concerns, the firm agreed to make the following amendments:

1. To ensure that the risk information appeared higher on the page, so that consumers cannot apply for a quote without having first seen the product warning.
2. To ensure that all advertised interest rates are presented correctly. In particular, where an introductory rate is stated, the terms of the deal will be clearly stated together with the future SVR and the overall cost for comparison APR.

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