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

FHFA to create affordable housing advisory committee

House releases text of amended housing bill ahead of vote

Mortgage
May 14, 2026

House leadership has released the text of its amendment for a bipartisan housing bill ahead of a possible vote on the legislation next week.

Treasury Department seeks feedback on stablecoins, illicit activities

Senate Banking Committee advances Clarity Act

Newsbytes
May 14, 2026

The Senate Banking Committee voted 15-9 to advance a market structure bill for digital assets. ABA and other groups continued to urge for further tightening of the prohibition on interest-like rewards for holding stablecoin.

Trump to nominate Miran for Fed board seat

Miran resigns from Federal Reserve Board

Newsbytes
May 14, 2026

Federal Reserve Governor Stephen Miran submitted his resignation as a member of the Fed board, effective when his successor is sworn in. He will be succeeded by incoming Chairman Kevin Warsh.

ABA offers recommendations for improving community investment programs

Report: FHLB mission programs generated $47B in economic impact

Mortgage
May 14, 2026

Federal Home Loan Bank mission programs generated an estimated $47.1 billion in economic impact between 2015 and 2024, although that figure could be as high as $94.8 billion, according to a new report by the Urban Institute.

ABA urges FCC to modernize calling rules, strengthen fraud protections

ABA supports issuance of ‘know your upstream provider’ proposal

Compliance and Risk
May 13, 2026

ABA expressed its support for FCC Chairman Brendan Carr’s decision to schedule a May 20 vote on issuing a proposal that would impose stronger “know your upstream provider” requirements on voice service providers that allow calls to pass...

ABA, associations urge Congress to overturn CFPB credit card late fees rule

House committee advances ABA-backed bills on bank supervision, fighting scams

Compliance and Risk
May 13, 2026

The House Financial Services Committee advanced two bills supported by ABA as part of a package of proposed legislation on topics ranging from fighting scams to AI. Both bills passed by unanimous vote.

NEWSBYTES

Mortgage rates slip

May 14, 2026

House releases text of amended housing bill ahead of vote

May 14, 2026

FDIC releases study of 2023 bank failures

May 14, 2026

SPONSORED CONTENT

Credit Memos at the Convergence Point

Credit Memos at the Convergence Point

May 1, 2026
Digital Account Opening: Think Outside the Box for Maximum Business Impact

Digital Account Opening: Think Outside the Box for Maximum Business Impact

April 29, 2026
Why Your Systems Keep Slowing Down — and What to Do About It

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

April 21, 2026
Planning Your 2026 Budget? Allocate Resources to Support Growth and Retention Goals

How leading banks are enhancing customer engagement through financial data insights

April 10, 2026

PODCASTS

Podcast: How consumer deposits drive full relationship banking

May 14, 2026

Podcast: How an Ohio banker talks with policymakers about stablecoin issues

May 6, 2026

Podcast: Tech transformation and AI to power bank growth

April 29, 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.