Further to the bulletin issued 07 July, as Google itself has never defined the term “APR”, following a suggestion given to a client’s web developer last week, it would appear Google are accepting that “advertisers should follow local legal requirements and the Google’s policies to be able to advertise with Google. About the APR, we will honor APR or any local equivalent.”
Google appear to have accepted “Nominal Annual Percentage Rates of Interest Charged (as defined by s.153 of the National Credit Code)” in lieu of “APR” as suggested and we are passing this information on to assist you comply with both Google’s new policy and your legislative compliance requirements under the NCCP Act, the National Credit Code and Regulations.
In the email to the developer, Google noted that many lenders are using “max per annum rate”. Please refer to our original bulletin as to why ASIC may not find this acceptable.
Please do not copy what any other lender may have done just to be expedient. It may cost you dearly given that strict liability criminal offence. If you need assistance, please seek it from well-qualified and knowledgeable, industry specific legal professionals.