Advertising customer financing honestly: a plumber's summary of the Canadian rules

Three sets of rules touch a plumbing financing ad

A single ad that says "New water heater today, pay over time" touches three different areas:

1. General advertising law, which applies to every claim you make, including claims about payment.
2. Credit-disclosure rules, which apply to the lender and to how credit terms are presented.
3. Anti-spam law, which applies when you send the message by text or email.

On top of these, a few provinces add their own consumer-protection rules, and Quebec has language requirements. Let's take each in turn.

Misleading advertising and drip pricing

The federal Competition Act prohibits false or misleading representations to the public. The Competition Bureau's guidance on misleading representations explains that the general impression of an ad counts, not just its literal words. A headline promising something the fine print takes away can still be misleading.

The Bureau also treats drip pricing as a problem: advertising a price that leaves out fixed, mandatory fees the customer will have to pay anyway. For plumbers, the risk shows up when an ad leads with a low monthly figure or a low "starting from" price that no real job ever matches.

What this means for your financing marketing:

• Don't advertise an outcome the lender hasn't confirmed, such as "everyone approved".
• Don't show a payment figure that only applies to an unrealistically small job.
• Don't bury conditions in a footnote that changes the meaning of the headline.
• Keep the job price itself honest. Financing doesn't fix a misleading quote.

Credit disclosure depends on the kind of lender

Who has to disclose what depends on who is lending. The Financial Consumer Agency of Canada (FCAC) page on personal loans explains that federally regulated lenders, such as banks, must give borrowers key information such as the loan amount, interest rate, term, payment amount and fees. It also notes that other lenders fall under provincial or territorial rules, and points consumers to their provincial or territorial consumer affairs office. FCAC's lines of credit page makes a similar point about required information for that product.

You don't need to master these rules, because the disclosure duty sits with the lender. What you do need is to avoid creating your own credit advertising outside the lender's control. In practice:

• Use only the lender's supplied examples, figures and disclosures.
• If you can't get the disclosures, don't use the figures. Say that payment options are available, subject to approval, and link to the lender's information.
• Keep copies of the lender's approval for any ad that mentions terms.
• When the program changes, update every page, ad and quote sheet.

Provincial consumer-protection offices

Each province and territory has an office that handles consumer protection, and some of their rules affect how home-service contracts are sold. Alberta, for example, licenses prepaid contractors under its Consumer Protection Act. A few offices worth knowing:

• Consumer Protection BC
• Alberta's consumer protection pages
• Consumer Protection Ontario
• Quebec's Office de la protection du consommateur
• Saskatchewan's Financial and Consumer Affairs Authority and New Brunswick's Financial and Consumer Services Commission

Our areas pages link the office for every province and territory. If you sell door to door, at home shows or by phone, check your province's rules on direct sales and cancellation rights before you design a campaign.

Texts and emails need consent

Follow-up messages about a quote or a financing option are commercial electronic messages. Under Canada's Anti-Spam Legislation, as the CRTC's CASL FAQ explains, they need the recipient's consent, must identify the sender and must include a working unsubscribe, and the sender must be able to prove consent.

For a plumbing company that means asking at the quote stage, recording the answer, and giving an easy way to stop. Our quote follow-up service builds those steps in.

Quebec: French comes first

If you advertise to customers in Quebec, the Charter of the French Language applies. French must be clearly predominant in commercial advertising, and websites aimed at Quebec customers must be available in French. The OQLF's business pages are the official reference. Lender materials will also need French versions; ask your lender whether they supply them.

A ten-point checklist before any financing ad goes live

1. Is the lender named, where the lender allows it?
2. Does the ad say, in some form, that financing is subject to the lender's approval?
3. Are all figures, rates or examples supplied by the lender, with their disclosures?
4. Does the headline still hold true once someone reads the fine print?
5. Is the advertised job price realistic for an actual customer?
6. Are there any words like "assured", "everyone", "instant" or "no credit check" that the lender hasn't approved? Remove them.
7. Will the landing page say the same thing as the ad?
8. For texts and emails: is consent recorded, is the sender clear, does unsubscribe work?
9. For Quebec: is the French version ready and predominant?
10. Do you have a dated copy of the final version and the lender's approval?

Where we fit

Keep a simple record

For each financing ad or page, keep the date it went live, the version of the text, the lender material it relied on and, if applicable, the lender's approval. A shared folder is enough. If a customer or regulator ever asks what you said and when, you'll be able to answer in minutes.

We are a marketing firm, not a lender, broker or law firm. We build your financing pages, ads and follow-up inside these limits and flag anything that needs a lender's or lawyer's eye. For the business side of whether financing pays, read the close-rate maths guide. Call, text or email to talk it through.