Promo Rates (& Similar)

podgerodge

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The Central Bank should be looking at the clear increase in recent times of "promotional rates", stating AER even though the AER cannot be achieved (due to e.g. 6 month introductory rate) and the forcing of clicking hyperlinks to see the full terms and conditions applying to the rate.

I recall that the original Consumer Protection Code (back in the 2010's while Sharon Donnery was involved in the Consumer side) that clear 'exclusions/*** etc.' had to be on the advert. Now, it appears, but I'm open to correction, that the current Consumer Proection Code only mandates a link/URL be provided to the detail.

It's becoming very difficult to 'judge a book by its cover' these day (thankfully helped by @Lightning for us on this site), and some of these promo rates are likely (or will) become worse than signing up for a straightforward AER from an institution not playing these games.

I note (following a search) that @Brendan Burgess mentioned way back in 2011 that the Central Bank found:

"However, banks are reminded that key information must always be brought to the attention of consumers. When determining whether advertising material is misleading or not, the Central Bank will always look at the advertising material from the perspective of the consumer. The following case study is an example of an issue identified during this theme, which has resulted in customer refunds:

Case Study 1
In the case of 1 deposit product, 2 brochures were examined and were considered to be unfair and misleading to customers. The brochures advertised an attractive equivalent annual rate but information relating to the minimum rate payable was not clearly presented to the customer and should have been highlighted for the customer, in accordance with Provision 12 of Chapter 2 of the Consumer Protection Code. Within 9 months of issuing the brochure, the rate payable on the account was the minimum rate. Therefore, we considered that customers were misled with regard to the actual rate that could be achieved.
The bank concerned is now in the process of recalculating the interest for each customer as if they had received the advertised rate for the entire year. Furthermore, the bank will inform customers that the refund is being processed.




Misleading advertising
In the case of one deposit product, two brochures were examined and were considered to be unfair and misleading to customers. The brochures advertised an attractive equivalent annual rate, and information relating to the minimum rate payable, which should have been highlighted, was not clearly presented to the customer. Within nine months of issuing the brochure, the rate payable on the account was the minimum rate. In this case it was determined that customers were misled on the actual rate that could be achieved. The relevant bank is now in the process of recalculating the interest for each customer as if they had received the advertised rate for the entire year, and refunds will be made.
 
It's becoming very difficult to 'judge a book by its cover' these day (thankfully helped by @Lightning for us on this site), and some of these promo rates are likely (or will) become worse than signing up for a straightforward AER from an institution not playing these games.

It has become more difficult to judge a book by it's cover.

Banks are advertsing AER rates that are impossible to achieve over the course of a year.

The list of 'promo rates' (or tactics to scoop up deposits and then take advantage of 'sleepy deposits' (as the industry calls them)) keeps growing.

And worse still some comparison sites like Consumerhelp.ie and Bonkers fail to make the promo aspect *crystal clear*. On Consumerhelp.ie:
- Raisin.ie Demand 'promo' rate that is only open to new customers and only applies for 3 months - but yet they fall into the trap and mislead - and claim the "Interest earned in 1 year" equates to the AER which it does not and rank the product at the top.
- MoCo 'promo' rate that applies to new accounts/customers only and applies to just the first few months - but yet they fall into the trap and mislead - and claim the "Interest earned in 1 year" equates to the AER which it does not.
- For Bunq 'promo' rate applies to balances in excess of the highest balances in the last half year - but yet they fall into the trap and mislead - and claim the "Interest earned in 1 year" equates to the AER which it does not.

Increasingly of the opinion that promo rates should be clearly segregated from ongoing rates.

But many rates are akin to promo rates but are difficult to label as such because they are different tactics.
- Avarda Bank via Raisin.ie rates go up and down like a yo yo. Not a promo per se. But they seem to scoop up deposits and then drop their rate and then rinse and repeat.
- Revolut having one rate under 2k and a much lower rate above 2k is a clear tactic so they can advertise a high rate even though it just applies to lower balances.

Promo rates are great if you are clued in and know how to take advance of them but most consumers are not that savvy.
 
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PTSB have a new Facebook Advertisment-

"Introducing our 32 Day Notice Savings Account, offering Ireland's highest interest rate on a notice account for personal customers. With no maximum balance, talk to us about growing your savings with PTSB."

Earn 1.25% AER.

Source: CCPC.ie


So, we have an Irish pillar bank advertising that they have the highest rate on a notice account in Ireland. And if you go to the CCPC website, ("Quickly find the best savings rates in Ireland. Compare the best deposit and interest rates using our comparison tools"), and filter deposit rates by "Notice Account" type, sure enough, you'll see that this fantastic rate is indeed truly Ireland's highest rate on notice accounts* (for banks listed!).

Of course, if you select "Instant Access", you'll have access to much higher rates from other banks. But who would want those rates, when you can lock yourself in for a month to secure this rate from PTSB.

It seems to me that CCPC, which is offering this comparison tool to assist people in getting the best rate for their savings, is being used by PTSB to make an advert that, while factually correct, might mislead some people with it's "Ireland's highest interest rate.." tag.

Others will disagree, I'm sure. Like to hear views. As stated, the advert is factually correct, and highly unlikely to be open to a complaint. But with "no maximum balance", I'm sure they believe some people will "talk to them" about "growing their savings" with a 1.25% rate!
ptsb highest variable interest.webp
 
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Ireland's highest variable interest rate notice account for personal customers

I would like to think anyone reading that would notice how many qualifiers are applied to make it true and assume there are better rates out there.
 
The government should be educating the general public on savings accounts on TV adverts. 1.25% for a 32 day notice is hardly good. With the savings and investment scheme supposedly on the way, it seems as though now would be a great time to educate the average person on the different options out there and what each one does.
 
Ireland's highest interest rate on a notice account for personal customers. With no maximum balance, talk to us about growing your savings with PTSB."

Earn 1.25% AER.

Source: CCPC.ie

Deeply misleading by PTSB for 3 reasons.

1. It is factually incorrect. BancaCF+ via Raisin 1 week notice account pays 2.02% and is the highest notice account rate available to Irish consumers.

2. CCPC do not list notice account products from Raisin at all. Hence, it is misleading for PTSB to use a non comprehensive comparison site as the basis for their claim.

3. Instant access and notice accounts are normally bundled together in terms of comparison. The highest instant access account rate for new customers is 3% or 3.51% if you include promotions or 2.45% if you include paid plans but not promos or 2.10% if you exclude promos, paid plans and new customer segmentations. Not 1.25%.
 
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The Advertising Standards Authority is a private agency which has no legal standing as an enforcement authority. The CCPC has powers. In this case I’d be complaining to the CCPC and the CBI
 
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