Report to the Congress on the Profitability of Credit Card Operations of Depository Institutions

June 2016

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iii

Contents

Introduction

Section 8 of the Fair Credit and Charge Card Disclosure

Act of 1988 directs the Federal Reserve Board to

transmit annually to the Congress a report about the

profitability of credit card operations of depository

here is based to a great extent on information from

the Consolidated Reports of Condition and Income

(Call Report) and the Quarterly Report of Credit

1 Refer to P.L. 100-583, 102 Stat. 2960 (1988). The 2000 report

covering 1999 data was not prepared as a consequence of the

Federal Reports Elimination and Sunset Act. The report was

subsequently reinstated by law.

1

Call Report Data

Every insured commercial bank files a Call Report each quarter with its federal supervisory agency.

While the Call Report provides a comprehensive balance

sheet and income statement for each bank, it

does not allocate all expenses or attribute all revenues

to specific product lines, such as credit cards. Nevertheless,

the data may be used to assess the profitability

of credit card activities by analyzing the earnings

of those banks established primarily to issue and service

credit card accounts. These specialized or monolined

banks are referred to here as “credit card banks.”

For purposes of this report, credit card banks are

defined by two criteria: (1) over 50 percent of their

assets are loans to individuals (consumer lending),

and (2) 90 percent or more of their consumer lending

involves credit cards or related plans. Given this definition,

it can reasonably be assumed that the profitability

of these banks primarily reflects returns from

The first credit card banks were chartered in the early

1980s; few were in operation prior to the mid 1980s.

To provide a more reliable picture of the year-to-year

changes in the profitability of the credit card

operations of card issuers, this report limits its focus

to credit card banks having at least $200 million in

assets. Most of these institutions have been in continuous

operation for several years, particularly those

with assets exceeding $1 billion, and are well beyond

the initial phase of their operations.

As of December 31, 2015, 13 banks with assets

exceeding $200 million met the definition of a credit

card bank. At that time, these banks accounted for

nearly 50 percent of outstanding credit card balances

on the books of depository institutions.

Tracking credit card profitability over time is complicated.

Accounting rule changes implemented in 2010

require banking institutions to consolidate onto their

Call Reports some previously off-balance sheet items

(such as credit card-backed securities). To the extent

that previously off-balance sheet assets have a different

rate of return than on-balance sheet assets, profitability

measures based on Call Report data in 2010

and after are not necessarily comparable to those

prior to 2010.

Another difficulty that arises in assessing changes in

the profitability of credit card activities over time is

that the sample of credit card banks changes somewhat

from one year to the next primarily because of

mergers and acquisitions. Thus, overall changes in

profit rates from year to year reflect both real

changes in activity and changes in the sample.

In 2015, credit card banks with assets in excess of

$200 million reported net earnings before taxes and

extraordinary items of 4.36 percent of average quarterly

assets (table 1). The level of earnings in 2015 is

down somewhat from that reported in 2014.

The decline in profitability in 2015 reflects a fall in

net non-interest income and a slight increase in provisions

for loans losses as a fraction of average assets,

which more than offset increases in net interest

income (table 2). Although provisions among the set

of credit card banks rose slightly, delinquency rates

and charge-off rates for credit card loans across all

banks were little changed in 2015, and continued to

Although profitability for the large credit card banks

has risen and fallen over the years, credit card earnings

have been almost always higher than returns on

3 Two depository institutions (Discover and American Express)

were included that did not quite meet these criteria, but can still

be considered credit card banks.

Delinquency Rates on Loans and Leases at Commercial

Banks,” www.federalreserve.gov/releases/chargeoff/.

3

2015 were consistent with historical experience: For

all commercial banks, the average return on all assets,

before taxes and extraordinary items was 1.30 percent

in 2015 compared to 4.36 percent for the large

credit card banks (table 2).

5 This report focuses on the profitability of large credit card

banks, although many other banks engage in credit card lending

without specializing in this activity. The profitability of the

credit card activities of these other banks is difficult to discern.

The cost structures, pricing behavior, and cardholder profiles,

and consequently the profitability of these diversified institutions

may differ from that of the large, specialized card issuers

considered in this report. In preparing many of the older annual

reports on credit card profitability, information from the Federal

Reserve’s Functional Cost Analysis (FCA) Program was

used to measure the profitability of the credit card activities of

smaller credit card issuers. These data tended to show credit

card activities were less profitable for smaller issuers than for

larger ones. The FCA program was discontinued in the year

2000. For further discussion, see Glenn B. Canner and Charles

A. Luckett, Developments in the Pricing of Credit Card Services,

pp. 652-666.

Table 1. Return on assets, large U.S. credit card banks,

2001–2015

Percent

Year Return

2001 4.83

2002 6.06

2003 6.73

2004 6.30

2005 4.40

2006 7.65

2007 5.08

2008 2.60

2009 -5.33

2010 2.41

2011 5.37

2012 4.80

2013 5.20

2014 4.94

2015 4.36

Note: Credit card banks are commercial banks with average assets greater than

or equal to $200 million with minimum 50 percent of assets in consumer lending

and 90 percent of consumer lending in the form of revolving credit. Profitability of

credit card banks is measured as net pre-tax income as a percentage of average

quarterly assets.

Source: Reports of Condition and Income, 2001–2015.

Table 2. Income and expenses for U.S. banks in 2014 and

2015

Percent of average quarterly assets

Income or expense

Credit card

banks

in 2015

Credit card

banks

in 2014

All

commercial

banks

in 2015

Total Interest Income 9.58 8.87 2.51

Total Interest Expenses 0.85 0.69 0.26

Net Interest Income 8.73 8.18 2.25

Total Non-Interest Income 4.41 4.54 1.49

Total Non-Interest Expenses 6.35 6.00 2.26

Net Non-Interest Income -1.94 -1.46 -0.77

Provisions for Loan Losses 2.43 2.17 0.19

Return 4.36 4.55 1.30

Note: Credit card banks are commercial banks with average assets greater than

or equal to $200 million with minimum 50 percent of assets in consumer lending

and 90 percent of consumer lending in the form of revolving credit.

Source: Reports of Condition and Income, 2001–2015.

4 Report to the Congress on the Profitability of Credit Card Operations of Depository Institutions

General Discussion

Bank cards are widely held by consumers and they

use their cards extensively. According to the Federal

Reserve’s Survey of Consumer Finances (SCF) about

70 percent of families had one or more credit cards in

2013. Consumers use credit cards for purposes of

borrowing, as standby lines of credit for unforeseen

expenses, and as a convenient payment device. As a

source of credit, credit card loans have substituted

for borrowing that in years past might have taken

place using other loan products, such as closed-end

installment loans and personal lines of credit. As a

convenient payment device, a portion of the outstanding

balances reflects primarily “convenience

use,” that is, balances consumers intend to repay

within the standard “interest-free” grace period

offered by card issuers. In fact, consumer surveys,

such as the SCF, typically find that somewhat over

half of card holders report they nearly always repay

their outstanding balance in full before incurring

The general purpose bank credit card market in the

U.S. is dominated by VISA- and MasterCard-labeled

cards that combined accounted for nearly 500 million

Discover accounted for another 110 million general

purpose cards in 2015. The combined total number

of charges and cash advances using such cards in

2015 reached 30.9 billion, involving over $2.9 trillion

dollars.

Although a relatively small group of card issuers hold

most of the outstanding credit card balances, several

thousand banking institutions and credit unions offer

bank cards to consumers and are free to set their

indicates that consumers carried nearly $938 billion

in outstanding balances on their revolving accounts

as of the end of 2015, about 5.2 percent higher than

Based on credit record data the amount of available

credit under outstanding credit card lines far exceeds

the aggregate of balances owed on such accounts.

Credit record data indicate that as of the end of 2014

individuals were using less than one-quarter of the

total dollar amount available on their lines under

available has risen somewhat since 2010, but is about

15 percent below its peak in 2008.

In soliciting new accounts and managing existing

account relationships, issuers segment their cardholder

bases along a number of dimensions including

by risk characteristics, offering more attractive rates

to customers who have good payment records while

imposing relatively high rates on higher-risk or latepaying

cardholders. Card issuers also closely monitor

payment behavior, charge volume, and account profitability

and adjust credit limits accordingly both to

allow increased borrowing capacity as warranted and

to limit credit risk.

Direct mail solicitations continue to be an important

channel used for new account acquisition and

6 The numbers from the 2013 SCF—the most recent survey available—

are little changed since 2010; for a discussion of credit

Family Finances from 2007 to 2010: Evidence from the Survey

7 Figures cited in this sentence and the remainder of the paragraph

8 Currently, over 5,000 depository institutions, including commercial

banks, credit unions, and savings institutions, issue VISA

and MasterCard credit cards and independently set the terms

and conditions on their plans. Many thousands of other institutions

act as agents for card-issuing institutions. In addition to

the firms issuing cards through the VISA and MasterCard networks,

two other large firms, American Express Co. and Discover

Financial Services, issue independent general purpose

credit cards.

9 Refer to www.federalreserve.gov/releases/g19/Current. Revolving

credit consists largely of credit card balances but also

includes some other types of open-end debt such as personal

lines of credit.

available at www.newyorkfed.org/microeconomics/hhdc.html.

5

account retention. After reaching an all-time high in

2006 of 7.0 billion direct mail solicitations, mailings

fell sharply as the recent recession emerged. Mail

data indicate that the retrenchment in mailings began

to reverse starting in the third quarter of 2009 as

prospects for economic recovery improved. Industry

data on mail solicitation activity indicate mailings

rebounded to 4.2 billion in 2011. The number of

solicitations has been smaller since then, reaching

3.4 billion in 2015.

11 Source: Data from Mintel Comperemedia. Refer to www

.comperemedia.com.

6 Report to the Congress on the Profitability of Credit Card Operations of Depository Institutions

Recent Trends in Credit Card Pricing

Credit card pricing and how it has changed in recent

years has been a focus of public attention and is consequently

reviewed in this report. Analysis of the

trends in credit card pricing here focuses on credit

card interest rates because they are the most important

component of the pricing of credit card services.

Credit card pricing, however, involves other elements,

including annual fees, fees for cash advances and balance

transfers, rebates, minimum finance charges,

addition, the length of the “interestfree” grace

period, if any, can have an important influence on

the amount of interest consumers pay.

Over time, pricing practices in the credit card market

have changed. Today, card issuers offer a broad range

of plans with differing rates depending on credit risk

and consumer usage patterns. The economic downturn

and new credit card rules spurred changes in

pricing in 2009 and 2010. In most plans, an issuer

establishes a rate of interest for customers of a given

risk profile; if the consumer borrows and pays within

the terms of the plan, that rate applies. If the borrower

fails to meet the plan requirements, for

example, the borrower pays late or goes over their

credit limit, the issuer may reprice the account

reflecting the higher credit risk revealed by the new

behavior. Regulations that became effective in February

2010 limit the ability of card issuers to reprice

outstanding balances for cardholders that have not

fallen at least 60 days behind on the payments on

their accounts. Issuers may, however, reprice outstanding

balances if they were extended under a

variable-rate plan and the underlying index used to

establish the rate of interest (such as the prime rate)

changes. The new rules continue to provide issuers

with considerable pricing flexibility regarding new

balances.

This report relies on credit card pricing information

from a sample of credit card issuers on

(1) the average nominal interest rate and (2) the average

computed interest rate. The former is the simple

average interest rate posted across all accounts; the

latter is the average interest rate paid by those cardholders

that incur finance charges. These two measures

can differ because some cardholders are convenience

users who pay off their balances during the

interestfree grace period and therefore do not typically

incur finance charges. Together, these two interest

rate series provide a measure of credit card pricing.

The data are made available to the public each

12 In June 1996, the Supreme Court ruled that states may not regulate

the fees charged by out-of-state credit card issuers. States

have not been permitted to regulate the interest rates out-ofstate

banks charge. In making its decision, the Court supported

the position previously adopted by the Comptroller of the Currency

that a wide variety of bank charges, such as late fees,

membership fees, and over-the-limit fees, are to be considered

interest payments for this purpose. This ruling will likely ensure

that banks will continue to price credit cards in multidimensional

ways rather than pricing exclusively through interest

rates. Source: Valerie Block, Supreme Court Upholds Nationwide

of the fees charged by credit card issuers is provided in

“Credit Cards: Increased complexity in Rates and Fees Heightens

Need for More Effective Disclosures to Consumers,” U.S.

Government Accountability Office, Report 06-929, September

12, 2006. Refer to www.gao.gov.

Figure 1. Average interest rates on credit card accounts

0

2

4

6

8

10

12

14

16

1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015

Interest rate, all card accounts

Interest rate, card accounts assessed interest

Two-year Treasury rate

Percent

Source: Quarterly Report of Credit Card Interest Rates

7

quarter in the Federal Reserve Statistical Release

Data from the FR 2835a indicate that the average

credit card interest rate across all accounts is currently

at a relatively low level of around 12 percent,

while the two-year Treasury rate, a measure of the

baseline or “risk-free” rate, has been close to zero

since mid-2011 (figure 1). Average rates on accounts

assessed interest are reported to be somewhat higher,

at closer to 14 percent as of the fourth quarter of

2015. It is important to note that while average rates

paid by consumers have moved in a relatively narrow

band over the past several years, interest rates

charged vary considerably across credit card plans

and borrowers, reflecting the various features of the

plans and the risk profile of the card holders served.

8 Report to the Congress on the Profitability of Credit Card Operations of Depository Institutions

0616

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