The UK Advertising Standards Authority (ASA) today issued a ruling against a paid-for YouTube ad for Prosperi Academy.
Prosperi Academy is an app offering financial investment training courses. The ad in question was seen on 25 October 2024.
The ad featured an individual who said, “How do you become the first millionaire in your family?”. Text that stated “START WITH $20” then appeared on-screen, alongside a screen-recording of an individual’s bank account which showed the balance increasing in real time as transactions occurred. Well-known logos, each accompanied by a button labelled “INVEST”, were then shown.
Next, a different individual who was described as a student was shown, accompanied by the text “Invested: $20 Income: $974”. A graph on-screen showed financial transactions quickly increasing in value, as the individual who was visibly excited, said, “Oh my god, what”.
The ad then showed another screen-recording of a bank account, in which the account balance increased again as transactions occurred. Smaller text at the bottom of the screen stated, “Prosperi, as a learning platform, does not provide any investment or financial advice. Your capital may be at risk.”
The complainant challenged whether:
- the investment return claims were misleading and could be substantiated;
- the ad was misleading because it did not make clear the risks involved in investment; and
- the ad was irresponsible because it took advantage of consumers’ inexperience and credulity.
The ASA acknowledged that the claims were intended to be inspirational and illustrative; they were not based on real data. However, the Authority considered that it was not made sufficiently clear in the ad that the investment return claims were fictional and because of that, consumers were likely to interpret them as real results.
In any case, even if it had been clear that the specific return claims were fictional, the overall impression of the ad was, nevertheless, that consumers would be able to make high investment returns by taking the advertiser’s courses. Because the ASA had not seen any evidence to demonstrate that, it concluded that the ad was misleading.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 3.7 (Substantiation).
Further, the ASA considered that the ad was seen on a non-specific platform and addressed to a general audience who were unlikely to have any specialist knowledge of financial investment.
The Authority acknowledged the ad contained on-screen text that stated, “Your capital may be at risk”. However, this text was in a small font placed at the bottom of the ad. The text was also partially obscured by a sponsored pop-up with a link to visit the Prosperi Academy website. That statement was therefore likely to be overlooked.
Furthermore, the ASA considered that the ad did not make explicitly clear that the value of financial investments could go down or explain how consumers’ capital might be at risk. The ad included several transactions that resulted in a profit, but did not include any transactions where a loss was made. The impression from the ad was that consumers could expect to make large sums of money rapidly, with minimal risk after investing. The ASA therefore concluded that the ad was misleading.
On that point, the ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising) and 14.4 (Financial products).
Also, the ASA considered that the impression that financial investment was straightforward and could be undertaken by anyone, no matter their level experience, was strengthened by the ad’s reference to a student seen rapidly making large amounts of money after investing. That suggested that groups who were likely to have fewer resources could easily improve their financial situation through investment and the use of Prosperi Academy’s product.
The ASA further considered that the options displayed in the ad of spending 5 minutes, 1 hour or 4 hours investing, suggested to consumers that they would not be required to spend significant periods of time using the Prosperi app to earn large amounts of money.
The Authority concluded that the ad took advantage of consumers’ inexperience and credulity by suggesting large returns could be made with minimal time and financial resources. Also, it irresponsibly suggested that financial investment was straightforward, and for everyone, regardless of personal financial circumstances.
On that point, the ad breached CAP Code (Edition 12) rules 1.3 (Social responsibility) and 14.1 (Financial products).
The ad must not appear again in the form complained of. The ASA told Zimran Ltd t/a Prosperi Academy to ensure that they held the relevant substantiation for the claims made in their ads. The ASA told them to ensure their ads made sufficiently clear that the value of financial investments could go down as well as up. The ASA also told them to ensure that they did not irresponsibly take advantage of consumer’s lack of experience or credulity by implying that financial investment was straightforward, and large returns could be made with minimal time and resources.
