GVH reportedly levied the fine for a month-long ad campaign of K&H’s “MIX” product early in 2014. K&H advertised a 7.80% annual return on the product – well over the market rate – but failed to make clear that the rate was paid only on the one-third of savings that were placed in a deposit, according to a report on the GVH judgement. The other two-thirds were put in a closed-end investment fund or life insurance policy.

GVH said it considered the scope of potential clients reached by the ads as well as two previous similar offenses by the lender in the past five years as aggravating factors.