ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Payments

Missing the point on credit card APR margins

March 6, 2024
Reading Time: 4 mins read
How Competitive Is the Credit Card Market?

Photo by Avery Evans on Unsplash

Contrary to showing anti-competitive behavior, as the CFPB misreads the data, credit cards are a competitive sector that has expanded credit access.

By Jess Sharp
ABA Data Bank

The Consumer Financial Protection Bureau recently reported that credit card interest rate margins — the difference between average APR and the prime rate — have increased in recent years. Based on its analysis of Federal Reserve consumer credit data, the CFPB concludes that APR margins are “excessive” and anti-competitive pricing behavior is to blame. While it is true that APR margins have increased, the CFPB ignores the root causes for this development. As a result, its conclusion that “high levels of [market] concentration…explain why credit card issuers have been able to prop up high interest rates to fuel profits” is demonstrably false.

The widening APR margin is driven by three factors:

  • An increase in the number of subprime accounts, which have higher APRs that reflect their credit risk.
  • A rise in revolving accounts, especially in the subprime tier.
  • A shift away from imposing annual fees on subprime accounts in favor of upfront pricing via the APR.

Combined, these forces illustrate how issuers have expanded access to credit cards after nearly 50 million subprime and prime accounts were closed in the aftermath of the 2008–09 recession, and are pricing risk accordingly. Rather than a reflection of anti-competitive behavior, the growth that has occurred in the credit card market over the last decade is evidence of a well-functioning and highly competitive industry making good on its commitment to expand access to affordable and sustainable credit to an increasing share of U.S. households.

Increase in the share of subprime accounts

The main cause of widening APR margins in recent years is the growth in subprime account volume. By definition, subprime accounts are riskier than prime and super-prime accounts, and as such they are typically associated with higher interest rates. According to Argus Advisory Services, the number of subprime accounts (defined as accounts with credit scores below 680) has more than doubled over the last decade (+113 percent), expanding at nearly twice the rate of prime accounts (+65 percent) and nearly three times the rate of super-prime accounts (+44 percent). Subprime accounts still comprise the smallest share of the market, but as their market share has grown, their influence on APR margins has increased.

In addition to the rising share of subprime accounts putting upward pressure on the APR margin, the relative degree of riskiness within the subprime tier has also affected the APR margin. Specifically, according to Argus data, the APR margin for subprime accounts rose by 3.1 percentage points from 2013 to 2023, roughly three times more than the change for super-prime accounts. This suggests the subprime accounts opened over the last 10 years have been somewhat riskier than the subprime accounts already active in 2013, and thus require a larger risk premium.

Increase in revolving rate

CFPB’s analysis focuses on the average APR for credit cards assessed interest (that is, accounts that revolve credit). As a result, some of the rise in the APR margin observed by CFPB over the last decade is attributable to the increase in the share of revolving accounts. According to Argus, the share of revolving accounts jumped from 41.7 percent in Q4 2013 to 45.7 percent in Q3 2023, representing the highest share of revolvers since 2011. Of the accounts that revolve, 42.3 percent are subprime, an increase of 7.6 percentage points from 2013. At the same time, the share of revolving accounts that are super-prime has fallen by roughly 4 percentage points over the same time horizon (from 27.7 percent in 2013 to 22.8 percent in 2023).

Because a larger share of accounts revolve, and because that change is driven by subprime accounts, it follows that the APR margin for accounts assessed interest would rise accordingly. Contrary to CFPB’s claims, however, this result is not due to “excess APR margins” or anti-competitive pricing behavior, but instead is due to simple market forces: there are more subprime accounts in the market, those accounts have higher APR margins due to the increased risk they pose to issuers, and they revolve at higher rates.

A shift to upfront pricing

CFPB has long advocated for transparent and upfront pricing via the APR. The CARD Act restricts issuers’ ability to reprice credit card loans based on risk as new information becomes available (for example, adjusting the APR to reflect payment behavior). This regulatory change led issuers to charge higher rates from the beginning, especially for subprime accounts that pose greater risk to the issuer (and are more likely to revolve).
Beyond risk-based pricing, issuers are also incorporating other pricing mechanisms into the APR. Using data from the CFPB’s 2023 CARD Act Report, the Consumer Bankers Association shows that credit card issuers have substantially reduced the use of annual fees for subprime and deep subprime accounts from 2015 to 2023. Instead, issuers are incorporating those fees into the APR, putting additional upward pressure on the APR margin.

On competition

Given these upward forces on the APR margin, CFPB’s conclusion that anti-competitive market behavior is to blame for the increase does not hold water — on the contrary, these forces indicate a movement towards greater pricing transparency in the market. As pointed out in a recent ABA Data Bank post and as demonstrated by the Department of Justice’s threshold for determining the degree of concentration in a given industry, the credit card market is highly competitive. It is a sign of this competitiveness that issuers have sought to expand the credit card market, and APR margins are thus evidence for the opposite of the CFPB’s conclusion.

 

Tags: ABA DataBankCompetitionConsumer lendingCredit cards
ShareTweetPin

Author

Jess Sharp

Jess Sharp

Jess Sharp is EVP for advocacy and innovation at ABA.

Related Posts

Fed releases agenda for upcoming conference on large bank capital requirements

Fed proposes to update rules on lending to bank insiders

Commercial Lending
July 31, 2026

For the first time in nearly 50 years, the Federal Reserve is proposing to comprehensively update the regulation governing extensions of credit to bank “insiders,” such as board directors, executives and major shareholders.

ABA faults banking regulators for confusing CRA rule rollout

FDIC, OCC propose to narrow Community Reinvestment Act scope

Community Banking
July 31, 2026

The FDIC and OCC proposed a series of amendments to Community Reinvestment Act regulations to “refocus” on the law’s objective of getting banks to meet the credit needs of their communities, including narrowing the list of qualifying activities...

Fed proposes to modernize mutual bank regulations

Fed proposes to modernize mutual bank regulations

Mutual Banks
July 31, 2026

The Federal Reserve proposed a new rule to “modernize” the mutual bank regulatory framework, including changes to expand access to capital and remove restrictions on converting to a stock company. ABA has long advocated for updating the framework.

ABA, Ohio Bankers League release ad encouraging Husted to keep fighting for Ohio families

ABA, Ohio Bankers League release ad encouraging Husted to keep fighting for Ohio families

Newsbytes
July 30, 2026

ABA and the Ohio Bankers League have released a new ad encouraging Sen. Jon Husted to continue his efforts to enact policies that help banks better serve their customers and communities and spur economic growth.

ABA’s Benda shares policy recommendations for fighting AI-enabled scams

ABA’s Benda shares policy recommendations for fighting AI-enabled scams

Compliance and Risk
July 29, 2026

Generative AI has made scams more convincing, personalized and scalable while enabling criminals to exploit trusted identities and communications channels, ABA's Paul Benda told senators.

Treasury Department seeks feedback on stablecoins, illicit activities

ABA, associations: Stablecoin review committee must establish formal procedures

Compliance and Risk
July 29, 2026

A new committee to review state-level regulatory frameworks for stablecoins must adopt strong, transparent rules before it starts making decisions “that will shape the payment stablecoin market for years to come,” ABA and three bankers associations said.

NEWSBYTES

Fed proposes to update rules on lending to bank insiders

July 31, 2026

Final: Consumer sentiment rose in July

July 31, 2026

FDIC, OCC propose to narrow Community Reinvestment Act scope

July 31, 2026

SPONSORED CONTENT

Why Your Systems Keep Slowing Down — and What to Do About It

Examiners Are Now Looking at Your Non-Core Systems

June 11, 2026
Your Floorplan Audit and Your Credit Decision Are Weeks Apart. That Gap Has a Price.

Your Floorplan Audit and Your Credit Decision Are Weeks Apart. That Gap Has a Price.

June 1, 2026
A Modern Blueprint for Serving High-Net-Worth Families

A Modern Blueprint for Serving High-Net-Worth Families

May 28, 2026
Why Your Systems Keep Slowing Down — and What to Do About It

AI Is in Your Bank. Is Your Cloud Contract Governing It?

May 20, 2026

PODCASTS

Podcast: Tactics for meaningful strategic planning

July 28, 2026

Podcast: Why it might be time to revisit a key FDIC ratio

July 23, 2026

Is Your Bank’s Wealth Business Built to Last?

July 23, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.