[Sean Cash]

Thoughts???

Dear AdWords Advertiser,

We’re writing to let you know about a change to Google’s advertising policies that might affect your AdWords account.

Beginning in the coming weeks, we will require all short-term loans advertisers to display the following prominently on the landing page:

1. Display the APR. Aggregators/lead generators may provide a representative APR range for their network.

2. Display the implications of non-payment, including the following:

- Financial implications (fees and interest)
- Collection practices
- Potential impact to users’ credit score
- Renewal policy information, including if the renewal is automatic and if there are fees associated with the renewal
- Aggregators/lead generators may provide sample implications from their network to satisfy the above requirements. Implications of non-payment should be grouped together in one location on the landing page.

The above must be displayed prominently, meaning the same font type, size, and color as the base text on the landing page. These guidelines apply to lenders, aggregators, and lead generators alike.

In addition, we are updating our policy on consumer advisories. Going forward, payday loan ads (a subset of short-term loans) will only be shown on Display Network sites that are related to payday loans. Ad serving in the Search Network will not change.

When we make this change, Google will suspend all campaigns identified as being in violation of our revised policy. Our system identified your account as potentially affected by this policy change. We ask that you make any necessary changes to your ads and sites to comply, so that your campaigns can continue to run.

We’ve given much consideration to our stance on the advertising of this content and the potential effect our policy decision could have on AdWords advertisers. However, as a business, Google must make decisions regarding the advertising that we accept. As noted in our advertising Terms and Conditions, Google may refuse any ads or terminate ad campaigns at any time, for any reason. You can view our Terms and Conditions at https://adwords.google.com/select/tsandcsfinder.

Sincerely,
The Google AdWords Team

[Finance1]

Interesting. I have to assume that it's directed at B2C only. I can't imagine B2B lending requiring this type of disclosure. This would go above and beyond St and Fed regulations. Especially for advances because we're very careful not call them "loans". This screams consumer protection and disclosure which most likely doesn't apply to the advance space.

[Sean Cash]

Interesting. I have to assume that it's directed at B2C only. I can't imagine B2B lending requiring this type of disclosure. This would go above and beyond St and Fed regulations. Especially for advances because we're very careful not call them "loans". This screams consumer protection and disclosure which most likely doesn't apply to the advance space.

You have way too much faith in Google. I ran an adwords campaign and it got off to a horrible start. Google shut off my ads after 2 days because their "filters" determined I was likely offering payday loans. I had to speak to 3 or 4 people at Google to try and explain that a merchant cash advance was a purchase of future merchant processing revenues, not a loan, and not for consumers (I used the explanation I would give merchants lol.). None of this made any sense to them. Eventually they unsuspended my account on the basis that I was an angel investor looking to help startups. WHAT?!

My point is this. Their e-mail says "we will require all short-term loans advertisers", not "B2C short-term loan advertisers." and "These guidelines apply to lenders, aggregators, and lead generators alike," not B2C lenders, aggregators, and lead generators.

An algorithm/filter will suspend accounts automatically that don't comply with the new rules. Tons of MCA folks were on that mass adwords e-mail, which means the filter will target them. Try convincing Google you don't need to comply with their rules and see how well that works

[Chambo]

and so it starts....full disclosure

[cashman]

OH man this is INTERESTING! The APR must be PROMINENTLY DISPLAYED on the LANDING PAGE with the same size text! That means it can't be tucked away at the bottom in a small font or on another page. IT HAS TO BE RIGHT THERE! It also says something about disclosing your collections practices. That's kind of weird I thought. Closing fees must be stated as well. Imagine that?

I just Googled short term business loans and clicked some ads to check out some of the existing landing pages. Some companies that will have to make serious changes to their landing pages:
American express
Lendio
HSBC
Forward Line
Bank of America
Swift Capital
And basically every cash advance company and lead generator...

Will being B2C get everyone off? I guess we will have to wait and see. I also wonder what Google will do to verify these figures. It will only take one company to claim they offer 4% APR merchant loans to ruin everyone else competitively if their real #s are up.

[cashman]

I just thought of this:

Since the rules only apply to the Adwords landing pages, you can create unique pages with all the rates terms just for paid clicks, but keep the rest of your site the same for organic traffic. Also if a merchant clicks around to other pages of your site, rates and terms don't need to be there, since they will have left the landing page. It almost makes me think that some people will find ways to beat the system.

[Sean Cash]

I guess if/when someone makes a change, it will be worth copying and pasting into this thread. Someone will come up with the best way and everyone will follow suit.

[miked]

I think that with all the money this industry spends monthly that Google is going to make some exceptions. Aren't they frantically looking for ways to make more money, not find ways to lose advertisers?

[Sean Cash]

Interesting. I have to assume that it's directed at B2C only. I can't imagine B2B lending requiring this type of disclosure. This would go above and beyond St and Fed regulations. Especially for advances because we're very careful not call them "loans". This screams consumer protection and disclosure which most likely doesn't apply to the advance space.

I'm responding to this comment again since I just picked up my mail today and saw the irony in something. I got an advertisement from Google to apply for their Adwords line of credit and of course it doesn't tell you much other than to apply. So I looked into this more online and it turns out Google doesn't feel they need to abide by their own policies. Is their initiative to "protect" consumers being done on their own initiative or are they being pressed by regulators? Either way, the rules apparently don't apply to them. If in fact some of us or our industry friends get their Adwords account suspended, here is a little something you can send to Google as a reply:

adwords biz credit.jpg

Rate as low as 8.99% APR* eh? Gotta love that star. All the terms are on another page in a smaller font, but I guess your ad would be less effective if people saw that. Back page says up to 18.99% APR. tsk tsk.

There are 2 pages you can apply through online.
1.
double standard.jpg
You can go online and apply but they want to collect information about you before they tell you anything. It literally tells you NOTHING.

2.
doublestandard1a.jpg
I couldn't find any these on any of the pages so far Google
- Collection practices
- Potential impact to users’ credit score
- Renewal policy information, including if the renewal is automatic and if there are fees associated with the renewal
- Aggregators/lead generators may provide sample implications from their network to satisfy the above requirements. Implications of non-payment should be grouped together in one location on the landing page.

Are you hiding them? Would less people give you their information if you put it there? Clicking apply takes you to Picture 1 directly above.

But then our favorite part:
When you actually go to apply for real, you are told even less:
double standard 2.jpg

There is some stuff on the right about fighting terrorism and that Google and their partner bank can use your information however they want and spam you via text message, phone, and pre-recorded auto-dials (LOL at this one).

double standard 3.jpg
Nothing at the bottom makes them compliant with their new policies either.

So they flash 8.99% APR, hide 18.99% as much as possible, and then fail to tell you any of the other things that they claim they are going to start enforcing. On 2nd thought though, this lack of disclosure does build the case that their new policies won't apply to B2C lenders. There are virtually no B2B lending disclosure regulations as Finance1 pointed out, especially since many of the transactions in this industry aren't even loans at all. So am I crying wolf over this whole announcement? Doubtful, considering I know many people who have received that e-mail. They did not say B2B, but rather "all short-term loans advertisers." I think that's what they meant.

If a big advertising disruption happens, someone better hold Google accountable to their own standards.

[cashman]

I can't say that I am shocked. This is what happens when the group policing the action is also in the same business. Take a look at this video that I pulled up. It sounds like an advertisement for cash advance except at the end, they say adwords advertising instead. heh.



Of course, you don't HAVE to advertise with google. There are alternatives, but obviously so many people use google that they are kind of like a dictator now. You can get all the benefits of living in the kingdom and just accept that the king can do what he wants or you can leave the kingdom and try to make it on your own out there. For many, it's more convenient to just live in the kingdom then to try and go out and start your own.

[Finance1]

I also got this e-mail. I am just going to leave thing unchanged and if something happens to my ads, adjust them afterwards. No use getting worked up about it before hand. My guess is this is for consumer loans like paydays, etc.

I'm still 99% sure that's exactly what this is targeted at. That industry is under major scrutiny. Not the MCA/Biz loan space. MCA's and biz loans are under virtually zero scrutiny. And they won't be any time soon.

The question we should ask ourselves is why is Google doing this? Because they are suddenly feeling like being an advocate for consumer protection and disclosure? Ha, not a chance. IMO- they are being pressured by regulators. That's the only reason I can see. Google is 100% in it to make money. They would never squeeze advertisers unless they are being forced too.

Google doesn't know the nuances here. They are simply targeting all advertisers that are in the loan space across the board. Clarification will follow shortly. And I'm still pretty much certain it's not going to affect biz loan providers.

[Chambo]

MCA's and biz loans are under virtually zero scrutiny. And they won't be any time soon.

Famous last words before the regulators walk in the door

[cashman]

Famous last words before the regulators walk in the door

Or maybe google's going to announce their own short term lending program and they want everyone else out of the picture.

check out the video on this
http://www.cnn.com/2012/12/06/opinio...ust/index.html

[Sean Cash]

I'm guessing you are kidding. They make way too much money from the ads and they have no liability.

[Finance1]

Famous last words before the regulators walk in the door

lol- not saying it's "impossible" to get regulated but this industry is far far from it. The microscope has come up a few times with zero impact. Rapid in 2008 tried to put the industry on the radar and of there have been a few high profile class actions with little collateral damage.

It's not even on the radar right now and I don't see it happening anytime soon. Regulators always focus on b2c stuff. B2B is largely left alone. In my home state of MD there is zero usary on any unsecured b2b loan above $15k. A handwritten contract on a cocktail napkin is binding too.

We are incorporated in VA. I have it in writing from the div of fin regulation that they have zero oversight on our business. There is not one single regulation in place irt cash advances.

If the meltdown didn't cause any regulations then I can't see anything sudden happening. Famous last words....LOL

[Chambo]

lol- not saying it's "impossible" to get regulated but this industry is far far from it. The microscope has come up a few times with zero impact. Rapid in 2008 tried to put the industry on the radar and of there have been a few high profile class actions with little collateral damage.

It's not even on the radar right now and I don't see it happening anytime soon. Regulators always focus on b2c stuff. B2B is largely left alone. In my home state of MD there is zero usary on any unsecured b2b loan above $15k. A handwritten contract on a cocktail napkin is binding too.

We are incorporated in VA. I have it in writing from the div of fin regulation that they have zero oversight on our business. There is not one single regulation in place irt cash advances.

If the meltdown didn't cause any regulations then I can't see anything sudden happening. Famous last words....LOL

Cocky attitudes and gross negligence will ALWAYS get the Regulators' attention.

[Chambo]

Only thing is, in today's environment, you would probably just see siome hefty fines levied to fill the municipal coffers. Question is, can your rogue 10 person handle a six figure levy? Heck, Can some of these MCA's handle it?

[miked]

so what's the story? Did google change anything or did someone cry wolf.

[Sean Cash]

It looks like the rules will only apply to loans that are 60 days or less in duration. So MCA companies will probably be in the clear exept that ads could automatically get suspended just because Google's algorithm infers that the company is offering short-term 60 day loans. If you have "advance" or "fast" or something else in your domain name, you could easily get mistaken for a short-term/payday lender. I guess we'll see. They haven't cracked down yet. All we have is the warning so far.

[textex]

If we did not get this email, are we in the clear? Our market is unsecured loans, not short-term loans. But Google did flex some muscle in the past requesting changes to be made that are in line with their previous short-term loan compliances.

[ct-advance]

ATTENTION every MCA company doing PPC, and in turn getting emails from google and almost having a panic attack. SEO is NOT HARD. Ranking for our keywords IS NOT HARD.

[MCNetwork]

Doing SEO properly and maintaining a high ranking is a full time job. It's not hard but it is very monotonous, tiring and time-consuming work and you are vulnerable to Google's ever-changing rules so you feel like a gerbil on a treadmill running furiously just to stay in the same place.