CFPB Releases Seventh Biennial Review of the U.S. Credit Card MarketĀ 

The Consumer Financial Protection Bureau (CFPB) has published its seventh biennial review of the consumer credit card market, as required under the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009. The report examines how credit cards are used, how issuersĀ operate, and how the market has evolved,Ā drawing onĀ data through 2024.Ā 

Credit cards continue to play a significant role in the financial lives of approximately 208 million Americans. For many consumers, they serve as a primary tool for everyday purchases, flexible expense management, credit building, and managing fluctuations in income and expenses.Ā The Consumer Financial Protection Bureau (CFPB) has published its seventh biennial review of the consumer credit card market, as required under the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009. The report examines how credit cards are used, how issuersĀ operate, and how the market has evolved,Ā drawing onĀ data through 2024.Ā 

Scope and MethodologyĀ 

The report analyzes consumer behavior, issuer practices, and structural changes in the credit card market. It revisits topics covered in prior CFPB reports—such as deferredĀ interestĀ products and marketplace innovations—while introducing new areas of focus for this review cycle. These include spending patterns by merchant category, promotional interest rate offers, and a more detailed examination of credit card transaction disputes.Ā 

Consistent with the CARD Act’s mandate, the analysis includes a focus on consumers with below-prime credit scores and evaluates issues related to the cost and availability of credit. The CFPB relied on a range of data sources as of 2024, including de-identified credit records and account-level data from large bank holding companies. The report highlights trendsĀ observedĀ since the prior biennial review, as well as longer-term developments that began before the COVID-19 pandemic.Ā 

Key FindingsĀ 

  • Overall credit card spending continued to expand, driven primarily by higher-credit-scoreĀ consumers.Ā Total purchase volume reached approximatelyĀ $3.6 trillionĀ in 2024, an increase fromĀ $3.2 trillionĀ in 2022. Spending growth of about 5 percent occurredĀ almost entirelyĀ among cardholders with prime-plus or higher credit scores. Purchase activity among consumers with prime or lower scores hasĀ remainedĀ largely unchangedĀ since late 2023, even as the number of those cardholders increased.Ā 
  • Outstanding balances climbed aboveĀ priorĀ benchmarks, though growth moderated.Ā Aggregate credit card balances surpassedĀ $1.2 trillionĀ in 2024. Average balances per cardholder rose above pre-pandemic levels in both 2023 and 2024, reachingĀ roughly $5,300Ā per month. Cardholders with prime credit scores carriedĀ significantly higher average balances, at approximately $8,700. Balance growth slowed to around 6 percent by the end of 2024, down from much higher rates seen in early 2022.Ā 
  • Interest rates increased to the highest levelsĀ observedĀ inĀ nearly aĀ decade.Ā The average APR for general-purpose credit cards rose to 25.2 percent in 2024, while private-label cards averaged 31.3 percent. These increases wereĀ largely tiedĀ to movementsĀ inĀ the prime rate. New general-purpose accounts opened in 2024 carried an average APR of 27.5 percent, compared with 19.8 percent for comparable accounts ten years earlier.Ā 
  • A growing share of cardholders relied on minimum-only payments.Ā In 2024,Ā roughly 15 percentĀ of general-purpose cardholders paid only the required minimum, an increase from the prior review period. For private-label cards, the share rose to 20 percent. The increase was most pronounced among consumers with subprime,Ā near-prime, and prime credit scores.Ā 
  • Consumer borrowing costs rose substantially. Interest charges totaledĀ $160 billionĀ in 2024, up significantly fromĀ $105 billionĀ in 2022.Ā Higher interest rates, an expanding cardholder base, and rising average balances all contributed to the increase. By the end of 2024, about half of all accounts carried revolving balances, consistent with pre-pandemic norms. Consumers also paidĀ $31.3 billionĀ in credit card fees,Ā representingĀ a 23 percent increase over 2022.Ā 
  • Cash backĀ products became the dominant general-purpose credit card offering.Ā Over the past decade, cash back cards grew from a minority share to more than one-third of all general-purpose accounts. Cards offering points or miles saw modest growth, while no-reward cards declined. Cash back cards are most often issued to consumers with stronger credit profiles and typically feature low or no annual fees and introductory zero-percent APR offers.Ā 
  • Promotional APR products accounted for a sizableĀ portionĀ of activity.Ā Credit cards with zero-percent introductory interest rates representedĀ roughlyĀ $899 billionĀ in purchase volume andĀ $352 billionĀ in outstanding balances by the end of 2024. Approximately one-third of total credit card spending and balances occurred on cards with promotional rates, which temporarily lower borrowing costs but tend to be associated with higher balances over time.Ā 
  • Delinquency and charge-off rates peaked before declining later in the year.Ā Credit card performance deteriorated in early 2024, with delinquencies and charge-offs reaching elevated levels, but conditions improved as the year progressed. ByĀ year-end, delinquency rates fell back to pre-pandemic levels, measuring about 3.0 percent for general-purpose cards and 3.8 percent for private-label cards.Ā 
  • Issuer market share varied significantly by consumer credit tier.Ā Issuers with assets underĀ $100 billionĀ heldĀ a majority ofĀ balances associated with below-prime consumers, while the vast majority ofĀ superprimeĀ balances were concentrated among larger institutions. Large issuers have competed for higher-credit-score consumers through enhanced rewards and benefits, while other issuers have focused on extending credit to lower-score consumers through specialized pricing, underwriting, and risk management approaches.Ā 
  • Disputed transactionsĀ remainedĀ a notable feature of card usage.Ā Cardholders challenged approximatelyĀ $9.8 billionĀ in charges during 2024, leading toĀ $5.9 billionĀ in chargebacks. Among general-purpose cards, cancelled recurring charges—such as subscriptions and membership fees—were the most common source of disputes.Ā 
  • Emerging technologies are reshaping competition and risk.Ā Advances in artificial intelligence and the use of alternative data sources are influencing how credit cards are marketed, underwritten, and managed. These tools have expanded access for consumers with limited credit history andĀ supportedĀ new consumer-facing debt management applications. At the same time, they have contributed to increased fraud risks. New payment alternatives, including stablecoins and pay-by-bank options, are also developing and may affect the structure of the credit card market over time.Ā 

Full ReportĀ 

The complete CFPB Consumer Credit Card Market Report providesĀ additionalĀ data, analysis, and methodological detail. It can be accessed here:Ā 
https://files.consumerfinance.gov/f/documents/cfpb_consumer-credit-card-market-report_2025.pdfĀ 

Author:Ā  Jennifer Evancic

Jennifer.Evancic@ResourceManagement.com

Jennifer Evancic is a third-party auditor valued by creditors and large organizations for her knowledge in call monitoring within the collections industry. With meticulous attention to detail and a firm grasp of regulatory requirements, she ensures compliance with clients’ criteria and state and federal regulations.

Jennifer audits collections calls, ensuring they meet client-specific criteria and comply with regulations, providing valuable insights and maintaining industry standards.

Beyond her auditing responsibilities, Jennifer takes the lead in organizing and facilitating monthly call calibrations. These sessions serve as a collaborative forum where clients and their vendors come together to discuss call monitoring results and address any findings or areas for improvement. Jennifer’s guidance fosters open communication and ensures alignment between clients and vendors, driving continuous improvement in collections practices.

Jennifer stays up-to-date with compliance and industry best practices by participating regularly in peer meetings, regulatory updates and industry webinars. This keeps her informed about emerging issues and ensures she remains a knowledgeable leader in collections compliance.

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