Background
This ruling forms part of a wider piece of work on social responsibility in ads for loans offered for Christmas.
The ads were identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules.
See also related rulings published on 18 March 2026.
Ad description
A paid-for Facebook post, for Smart Money Cymru Community Bank, seen in November 2025, stated, “Christmas is a time for giving, celebrating, and making memories – not worrying about money. Our affordable Christmas Loans are here to help you enjoy the season without the stress. Apply today and make this Christmas one to remember” [Santa Emoji, Christmas Tree Emoji]”. It included an image with wrapped Christmas presents and decorations at the top and text that stated, “Your Festive Finances, Sorted! Smart Money Cymru are here for you this Christmas”.
Issue
The ASA challenged whether the ad irresponsibly encouraged consumers to spend more than they could afford by taking out a loan to fund Christmas spending.
Response
Smart Money Cymru Credit Union Ltd t/a Smart Money Cymru Community Bank stated the purpose of the ad was to encourage people who were worried about their finances to look for an alternative and appropriate solution at a potentially stressful time of year. They asserted most responses to the ad came from existing members and that they did not encourage members or the wider public to borrow more than they could afford, but to borrow responsibly if needed. They stated they had reduced their individual borrowing limit from £15,000 to £7,500 the previous year to reduce the risk of bad debt, and that they continued to work closely with the Welsh Government to tackle financial exclusion.
Smart Money Cymru Community Bank accepted the importance of responsible advertising and acknowledged how the ad could have been perceived. They stated the ad was no longer running, would not be repeated in its current form and that they would review how they managed similar advertising in future.
Assessment
Upheld
The ASA acknowledged that credit unions were often the only option of financial assistance for many consumers who would not be considered creditworthy by mainstream banks and who might otherwise turn to high-cost or illegal money lenders to obtain credit. We also understood that credit unions provided services which helped their members build their credit rating. However, as with any credit provider, consumers would be required to repay what they had borrowed, with interest, and there would be consequences if repayments were not made on time. The ad promoted Smart Money Cymru Community Bank’s Christmas loans, and we therefore focused our assessment on whether the ad presented that product responsibly.
We considered that consumers were likely to understand the claims “Christmas is a time for giving, celebrating, and making memories – not worrying about money” and “Our affordable Christmas Loans are here to help you enjoy the season without the stress” to mean that by taking out a Christmas loan, consumers could avoid financial worry associated with Christmas. Further, we considered they, and the claim “Apply today and make this Christmas one to remember”, implied consumers could also spend more than they would otherwise be able to afford. We considered the overall presentation of the ad encouraged consumers to borrow excessively for festive spending, in a way that made light of the decision to take on debt.
We acknowledged that Smart Money Cymru Community Bank said it had withdrawn the ad. However, for the reasons stated, we concluded that the ad encouraged consumers to take out a loan to fund Christmas spending in a way that was irresponsible and therefore breached the Code.
The ad breached CAP Code (Edition 12) rule 1.3 (Responsible advertising).
Action
The ad must not appear again the form complained of. We told Smart Money Cymru Community Bank to ensure that future ads did not irresponsibly encourage excessive spending through the use of credit, particularly in relation to Christmas.
