Advertising roof financing honestly: what the rules expect

Three sets of rules that meet in one ad

When a roofing company advertises financing, three separate rulebooks overlap.

1. Cost-of-credit disclosure law. Provinces regulate how the cost of consumer credit is disclosed, including in advertising. Federally regulated banks have their own federal rules.
2. Misleading-advertising law. The federal Competition Act prohibits false or misleading representations to the public, whatever the product.
3. Your lender agreement. Most programs set rules about what dealers can say, which logos they can use and which materials need approval first.

On top of those, Canada's anti-spam law governs any commercial text or email you send about financing.

You don't need to master all three. You need to know when an ad moves from "simple" to "needs checking", and who to check with.

Cost-of-credit disclosure: what triggers it

In 1996, federal and provincial consumer ministers agreed in principle to a harmonized approach to cost-of-credit disclosure. The Consumer Measures Committee's harmonization agreement sets out a template that provinces then put into their own laws. It covers loan disclosure statements, the annual percentage rate (APR) and advertising.

Its advertising section is the part that matters to a roofing marketer. In summary, if an ad states specific cost details, such as an interest rate or a payment amount, the template expects the ad to disclose the APR and the term as well, and for credit offered through a supplier, the cash price. It also addresses ads that claim credit is interest-free. Radio and television ads have some exemptions in the template.

Because each province implements the template in its own legislation, details and wording vary. That's why the practical rule is simple: if your ad names a number about the loan, get the exact wording from your lender and confirm it meets the rules in your province. Each of our region pages links the provincial consumer-protection office.

A quick classification

Misleading-advertising risks in roofing

The Competition Bureau enforces the federal rules against false or misleading representations. Its material on environmental claims and drip pricing is worth reading because both issues come up in roofing marketing. Drip pricing means advertising a price that leaves out mandatory fixed fees. Environmental claims include phrases like "energy-saving roof" or "eco-friendly shingles".

Financing ads in roofing tend to go wrong in a few predictable ways:

• A monthly figure that ignores fees. If a dealer or application fee is mandatory, a low headline payment without it can mislead.
• "Starting from" payments based on a job nobody buys. A payment calculated on a tiny roof, when your typical job is far larger, gives a false impression of what most homeowners will pay.
• Urgency that isn't real. "Financing offer ends Friday" when it doesn't end Friday.
• Implying the roofer decides approval. Phrases like "we'll get you approved" suggest control you don't have.
• Bundling green claims. Saying a new roof "pays for itself in energy savings" needs evidence, and financing ads often carry these claims without it.

The safest habit is to ask of every line: could a reasonable homeowner come away with a wrong idea about what they'll pay or whether they'll qualify?

Your lender agreement comes first

Most lender programs for home-improvement dealers include marketing rules. Common ones include:

• approval of any material that mentions the program before it's used
• restrictions on naming the lender or using its logo
• required disclaimers, such as "subject to credit approval"
• a ban on advertising rates or promotional terms that aren't currently offered
• rules on who may help a homeowner with an application

Read yours, or ask your lender for its dealer marketing guide. If it's silent on something, ask before you publish. The financing pages service builds a lender review step into the timeline for exactly this reason.

Texts and emails about financing

If you follow up on estimates by text or email, and you should, Canada's anti-spam legislation applies. The CRTC's CASL FAQ explains the basics: commercial electronic messages need consent, must identify the sender and must include a working way to unsubscribe, and the sender should be able to prove consent.

For roofing companies, the practical steps are:

1. Ask for consent at the estimate and record it, with the date and how it was given.
2. Identify your company in every message.
3. Include a simple opt-out, such as "Reply STOP to opt out", and honour it promptly.
4. Keep financing wording in messages identical to your lender-approved description.

Our estimate follow-up service is built around these steps.

A pre-publication checklist

Before any financing ad, page, flyer or message goes out, run through these questions:

1. Has the lender approved this wording, if the agreement requires it?
2. Does it state a rate, payment, term or interest-free period? If so, is every required disclosure present and taken from the lender's materials?
3. Does it say or imply that approval is certain, or that your company decides?
4. Is any price shown complete, including mandatory fees?
5. Are any energy or environmental claims supported by evidence you could produce?
6. Is the offer actually available now, in this province?
7. If it's a text or email, do you have recorded consent and an opt-out?
8. Would your best estimator be comfortable explaining every word to a sceptical homeowner?

If any answer is "not sure", hold it until you know.

Where to get proper answers

Roofing.Finance summarises public rules so owners know which questions to ask. For the answers themselves:

• Your lender partner, for program terms, approved wording and disclosure documents
• Your provincial consumer-protection office, for provincial credit and direct-selling rules; for example, Consumer Protection Ontario or Consumer Protection BC
• A lawyer, for anything that turns on interpreting a statute or your contract

For the marketing side, see the guides overview or the FAQ.