Still Digging: Help Out Of The Hole

Still Digging: Help Out Of The Hole

In my last blog I looked at the Scottish Government’s new “Help out of the Hole” campaign to promote the Debt Arrangement Scheme. In particularly I looked at the wisdom of directing all offline traffic from their six week TV campaign to a new online landing page, rather than to their site.

Since then, to help people out of the hole of trying to find their new landing page, the Scottish Government has launched a pay per click campaign to promote their adverts for the site every time someone searches on Google.

This would appear sensible, as there is no point launching a six week TV campaign if no-one can find the landing page that you are directing them to, particularly as the site is no longer organically ranking first on Google for the term “Help out the Hole.”

That place has now been occupied by an imitation site, as I predicted it would last week.

What is more worrying, however, is the decision to now extend the pay per click campaign to compete for terms like “Debt Arrangement Scheme”.


Well whereas “Help out of the hole” is unlikely to cost them more than a couple of pence per click, as no-one else is running such a campaign and it is a low traffic search term; “Debt Arrangement Scheme” is in contrast a high traffic search term and the Scottish Government could be paying anything from £6 to £20 per click.

The reasons for this is their quality score on Google for that term using their new landing page is likely to be quite low; whereas in contrast their score for the same term using their site is likely to quite high, so they would pay less.

It appears clear the marketing strategy for the new campaign is to drive traffic to their new landing page, which is being used to measure the success of the campaign based on the number of visitors to the page. However, considering the page re-diverts visitors back to the site and a pay per click campaign for that site would cost less, it must be wondered whether the campaign objectives to promote the Debt Arrangement Scheme have been hijacked by the need to show the original strategy was in fact the correct one.

Considering this will come at a cost to the public purse, would it not be wiser to admit the original strategy of directing traffic to an obscure landing page was wrong?

It also has to be questioned whether the Scottish Government running a pay per click for high search traffic terms can be justified in the first place.

Most private firms can do this as they are prepared to incur the costs in the hope conversions from applications will justify the marketing costs. The Scottish Government cannot do this and actually their objectives are different as the purpose behind their campaign is to raise public awareness of the Debt Arrangement Scheme. One must wonder whether their money would have been better spent advertising on channels like Facebook, which in Scotland has over 3 million accounts registered and the cost of diverting traffic to a new landing page from there would have been dramatically less than it will be using their pay per click campaign. Also diverting traffic from an online channel to another is significantly easier than it is diverting them from an offline channel (TV) to an online one, as it just involves one click.

My view of this campaign is I fully support the strategy of using a public information campaign to promote the Debt Arrangement Scheme. I believe, however, the tactic of diverting offline traffic from a TV campaign to an obscure online landing page was wrong, particularly as there was already a well-established government site that could have been used.

I support the use of a pay per click campaigns for the new landing page, but believe extending the campaign to bid for high traffic search terms like Debt Arrangement Scheme is fundamentally ill-conceived and will come at a cost to the public purse; even more regrettable as if the established site had been used, the costs would likely be less to the public purse. This to me is indicative that the campaign strategy is now to drive more traffic to the new landing page and shore up the flailing Help out of the Hole campaign.

I also fundamentally must question the logic behind a public information campaign becoming involved in pay per click campaigns for high traffic search terms. The Scottish Government campaign, using such tactics, can never create any more than a ripple as it is time and budget limited, whereas their competitors will be there for the rest of the year. The Scottish Government would have been wiser investing more of their marketing budget on social media channels like Facebook, which are significantly less expensive and would drive more traffic to their landing page at a lesser cost to the public purse. They would also be more effective at helping realise the objectives of the campaign, which was to raise public awareness of the Debt Arrangement Scheme.

Scottish Government: Stop digging!

Scottish Government: Stop digging!

In launching its new campaign for the Debt Arrangement Scheme, it has to be wondered whether the Scottish Government has dug itself a hole, rather than helping debtors out of one.

The Campaign, which directs debtors to a new website called appears marketing madness, but will be supported by a six week TV campaign on STV, Channel 4 and Channel 5.

It directs people to the new website, which with its long URL address took me three or four attempts and a number of double checks before I got it correct: was it “help out the hole”, “get out the hole” or as Google suggested “help out of the hole of no hope”. It certainly felt like the latter.

Eventually a direct link from the Accountant in Bankruptcy’s website got me there.

Even trying a word search of Google was no help, unless of course I was looking for Australian miners stuck in a hole, someone called Rebecca who was unfortunately also in a hole or I was wanting to help find an instrument of vocaloid song, none of which I did.

The strategy behind this marketing campaign is hard to understand. It could be by directing debtors to a campaign specific site, the success of the campaign could be measured by the number of visitors to the site, but then surely a more memorable and relevant URL address could have been found. Equally, how effective is such a strategy if few find their way there.

If the strategy was to direct more Scots to a site where they could  get relevant and reliable debt advice, then why not make the call to action: google “Debt Arrangement Scheme” or “Das Scotland”, where most of those searching would have found after four or five sponsored ads, the Scottish Government’s ranks organically number one.

Alternatively, if the idea was to direct debtors away from those types of keywords, which are heavily bid for by private debt management companies, then any benefit is likely to be fleeting.

If it becomes clear heavy amounts of traffic are being directed towards the hole, then pay per click campaigns will be re-diverted and those remaining variations of the URL, that weren’t bought up by the Scottish Government on the 5th of August, will soon be taken.

It’s inexplicable, to me anyway, why the Scottish Government didn’t just direct visitors to its already established DAS website, which is highly ranked on search engines for Debt Arrangement Scheme related keywords, if not first and benefits from the authority of a domain name.

I suspect the campaign has been set up to measure its success by directing debtors to a specific site. The problem is because that site is hard to find and doesn’t capitalise on the search engine history of the official site, one must wonder whether success is being forsaken to measure success.

Maybe the Scottish Government need to heed the advice often given to debtors and stop digging.

Trust Deed Bubble to Burst

Trust Deed Bubble to Burst

No one should be in any doubt, the Scottish Government’s new proposals for Protected Trust Deed reform is about taking the heat out of the Protected Trust Deed market and ending the trafficking of debtors between lead generation and personal insolvency firms.

It’s no secret that with some firms now reportedly paying in excess of £2,000 for referrals, Scotland’s Trust Deed market has become an overinflated bubble with debtors being “mis-sold” products as new lead generation firms sprout up daily and chase down every possible lead for the lucrative fees that some firms are now dangerously paying.

The exorbitant fees have resulted in saturation level TV and radio campaigns that push and sell statutory remedies as products and don’t promote best advice. For some firms, the use of the products themselves in their company names, like Trust Deed, give away the game.

However, what many debtors are unaware of is in actual fact many of these firms are just lead generators whose entire business model is about trafficking debtors to insolvency firms for ridiculous referral fees. In addition to this, many debtors don’t realise that such levels of fees have created a high risk culture of mis-selling, with many being pushed into solutions that are not appropriate and are destined to fail when payments are not maintained and debts are handed back; but only after the lead generator has been paid and the debtor has made months of contributions towards a remedy that was never going to work.

The practice of paying fees has been allowed in Scotland since 2008, but only for work done. The logic being where someone else has gathered information about a debtor and passed it to an Insolvency Practitioner, then it is acceptable for that practitioner to pay that intermediary for the work they have done. This removes the need for the practitioner to do the work and prevents duplication, although they are still obliged to validate the information provided.

However, whereas such fees began at £2-300, they have exploded in recent years with some English firms now paying in excess of £2,000 per referral, allowing them to buy up significant portions of the Scottish Market.

However, the new Protected Trust Deed regulations which will be laid before the Scottish Parliament in early September and are expected to come into force by November are the clearest sign yet that the Scottish Government intends to curb the practice and clamp down on the mis-selling culture.

The new provisions that will be introduced will no longer allow trustees to recover referral fees as part of their outlays for a case and instead will require them to include them as debts into the case, where they will only receive a dividend on the fees and be treated like other creditors.

The way trustees charge their fees against cases will also change, meaning they will no longer be able to charge on a time and line basis and will have to propose a setup fee at the outset to creditors, with proposals thereafter only to take a percentage of the ingathered funds from the case. Effectively this will mean trustees will have to share the risk of the case failing with the creditors throughout the lifetime of the case and, logically ensure only those cases likely to succeed are taken on at the outset.

In addition to this new provisions will be brought forward extending the minimum time a trust deed lasts from 3 to 4 years, whereas the duration a debtor pays into a bankruptcy will, for the time being anyway, remain at 3 years. This means many debtors faced with the prospect of having to pay a trust deed for 4 years are more likely to opt for a bankruptcy where they will only pay for 3 years; or alternatively where they want to avoid that remedy and can repay their debts within a reasonable timeframe, a debt payment programme under the Debt Arrangement Scheme.

The only obvious conclusion that can be drawn from a consideration of these proposals, is that the Scottish Government are determined to take the air out the over inflated bubble that is the Scottish Trust Deed market.

And who can blame them?

The current state of the market is now at a dangerous level. The risks of mis-selling are high and many vulnerable debtors are now being targeted by firms, who to put it simply should not be advising anyone on anything and it would not be unfair to call them rogues.

The end result will probably be more sequestrations and a greater uptake of the Debt Arrangement Scheme by debtors. It will also probably mean that the high profile TV and radio campaigns will also come to an end as the commercials behind such campaigns will no longer be sustainable. We are also likely to see more insolvency firms, who are far better regulated by regulatory professional bodies, having to market themselves directly to consumers.

If this leads to better advice and less mis-selling, then that’s no bad thing.

I am looking forward to it and being able to breathe again.