A recent decision from the National Advertising Division offers important guidance for advertisers relying on customer surveys to substantiate performance and consumer perception claims. In NAD Report #7528, NAD evaluated whether survey results could support a series of claims made by Monarch Money, a subscription-based personal finance app. The Decision underscores familiar pitfalls in survey design, question framing, and claim alignment.

The Claims at Issue

Monarch advertised that users of its app would achieve concrete financial benefits and improved financial confidence, including claims that:

• Members save an average of $200 per month;

• Users gain a “clearer picture of their money”;

• “7 in 10 couples” report improved money conversations; and

• “8 in 10” users feel more in control of their finances.

All of the challenged claims were based on the results of a random survey of (non-incentivized) Monarch users. The survey relied exclusively on yes‑or‑no questions, without offering respondents an “I don’t know” or “Not sure” option. NAD found that this forced‑choice methodology alone undermined the reliability of the resulting data. NAD also took issue with the specific claims for additional reasons: 

Objective Average Savings Claim

To support the claim that “members save $200 per month on average,” Monarch relied on a survey question asking whether respondents had, “as a result of joining Monarch,” “reduced unnecessary spending or saved more than [they] had been saving.” NAD concluded that the question impermissibly conflated distinct financial behaviors, i.e., increased savings, reduced spending, and net cash flow.

NAD reiterated that survey questions used to substantiate performance claims must clearly isolate the specific behavior being measured, noting that ambiguous questions that capture multiple behaviors cannot reliably support a quantified savings claim. NAD also noted that respondents were asked to provide spur‑of‑the‑moment estimates rather than analyze their financial records, an approach NAD has previously cautioned against where accurate recall is difficult. Compounding these issues, NAD found that the advertising claim was framed as an objective performance assertion, while the underlying evidence consisted entirely of subjective consumer estimates. NAD emphasized that claims derived from surveys should not be presented as definitive factual outcomes or imply that a product’s performance has been directly measured if it has not. For these reasons, NAD recommended that the $200 savings claim be discontinued. 

“Clearer Picture” Claim 

NAD applied similar reasoning to Monarch’s “clearer picture of their money” claim. The supporting survey question asked whether users believed they had learned “where your money is going better than you understood before.” While a large majority of respondents answered “yes,” NAD found the question measured only improved visibility into spending using the app, a narrower concept than the broad financial clarity conveyed by the advertising claim.

NAD cautioned that evidence measuring a limited aspect of consumer experience cannot support broader performance or perception claims. Given the mismatch between the narrow survey question and the expansive claim—and the use of a forced yes‑or‑no format—NAD concluded that the evidence was insufficient and recommended discontinuation of the claim. 

Couples Claim

The decision also addressed a claim that “7 in 10 couples say Monarch improved their money conversations with their partner.” NAD found multiple deficiencies in the supporting survey evidence. Individual respondents were asked whether they had better financial conversations with “a partner,” but the survey did not establish whether respondents were part of a couple, did not confirm that respondents and their partners shared the same view, and did not define “partner."

NAD concluded that the survey’s design failed to support a claim framed as reflecting the views of couples and recommended that the claim be discontinued. 

“In Control” Claim

Finally, NAD evaluated Monarch’s claim that “8 in 10 feel more in control of their finances with Monarch.” Although the survey question directly asked whether joining Monarch made respondents feel more in control—and the claim closely tracked that language—NAD nevertheless found the evidence inadequate due to the forced yes‑or‑no response format, underscoring that even where a survey question aligns closely with the advertising claim, methodological flaws can still render the results unreliable for substantiation purposes. NAD again recommended that the claim be discontinued.

Key Takeaways for Advertisers

This decision serves as a reminder that survey-based substantiation must be approached with care. Advertisers should ensure that survey questions precisely match the claims they are intended to support, avoid forced‑choice formats that may inflate affirmative responses, and refrain from presenting subjective consumer perceptions as objective, quantified outcomes. As NAD’s analysis makes clear, shortcomings in survey design can undermine even well‑intentioned efforts to ground advertising claims in consumer feedback.