The Swedish Consumer Agency announce criticism of online rewards pages that promote consumer credit

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On June 2, 2020, the Swedish Consumer Agency announced its criticism of online rewards pages that promote consumer credit. The agency has examined eight such pages and noted the shortcomings of all. The audit has been conducted in the light of the requirement of moderation in § konsumentkreditlagen (2010: 1846) (KkrL) and the information requirements in § 7 and § 7 b of KkrL. Prices reviewed may be by the aforementioned provisions. Emphasizing the speed argument through placement in prominent places in the marketing through headline form and bold text style has been considered contrary to the requirement of moderation. The consumer could perceive credit as a simple and quick solution to financial problems and thus lock in a credit agreement without considering the consequences. Marketing credits by stating an interest rate is also considered to be contrary to the requirement of moderation. A discount rate can mislead consumers about the financial consequences of credit and entice them to make unforeseen decisions.

Most comparison sites have been considered to violate the information requirements in Kkrl, among other things when the information on the credit interest rate has been presented as a monthly interest rate. It is important that such information is stated as annual interest for the consumer to easily compare. Furthermore, the Swedish Consumer Agency has considered that when information on high cost credits is not enough, the information is stated at the top of the website. In order to the requirement in SEK 7 b to be considered to be fulfilled, the information must be provided for each individual credit offer that relates to a high-cost credit. The Swedish Consumer Agency has also concluded that the comparison pages are covered by the Act (2002: 562) on electronic commerce and other information society services (e-commerce law), since the services are considered to fall within the concept of “information society services”. This means that all comparison sites must fulfil the requirement for information in accordance with Section 8 of the e-commerce Act. In this regard, the Agency has determined that most of the comparison pages have not provided information in a correct and simple way. The Swedish Consumer Agency has noted that some of the comparison sites have not provided sufficient information about the provider of the website (for example, name and address were missing) and that the majority of them have made the information difficult to access. The Consumer Agency will follow up the review next year and will open cases against those who have not rectified the shortcomings.