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Te Winners and Losers of Credit Card Deregulation

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Te Winners and Losers of Credit Card Deregulation !%*' +"$$&'$%'&'% &"(&& )#("%$ Jennifer Wheary and Tamara Draut BORROWING TO MAKE ENDS MEET SERIES About Dēmos Dēmos: A Network for Ideas & Action is a non-partisan public policy research and advocacy organization committed to building an America that achieves its highest democratic ideals. We believe this requires a democracy that is robust and inclusive, with high levels of electoral participation and civic engagement; an economy where prosperity and opportunity are broadly shared and disparity is reduced; and a strong and effective public sector with the capacity to plan for the future and provide for the common good. Founded in 2000, Dēmos’ work combines research with advocacy—melding the commitment to ideas of a think tank with the organizing strategies of an advocacy group. #e Economic Opportunity Program addresses the economic insecurity and inequality that characterize American society today. We offer fresh analysis and bold policy ideas to provide new opportunities for low- income individuals, young adults and financially-strapped families to achieve economic security. Dēmos A NETWORK FOR IDEAS & ACTION Miles S. Rapoport, President Tamara Draut, Director, Economic Opportunity Program For more information: Tel: 212-633-1405 | Fax: 212-633-2015 [email protected] | www.demos.org 220 Fifth Avenue, 5th Floor New York, NY 10001 Borrowing to Make Ends Meet - Series Information Who Pays? is part of a new Dēmos publication series that examines trends in household indebtedness and its impact on economic security. #e first report in the series, A House of Cards, chronicled the housing boom and the subsequent refinancing wave. #e second report, Borrowing to Stay Healthy, examined how medical expenses impact household credit card debt. Other reports in the series will offer new research and analysis on debt among low- and middle-income households, examine the driving factors behind the rise in debt, and advance innovative policy solutions for improving the economic stability of America’s households. %" *!" "!" !#!!$# Jennifer Wheary and Tamara Draut BORROWING TO MAKE ENDS MEET SERIES &' ( ) Dēmos Board of Trustees Stephen B. Heintz, Arnie Miller Charles R. Halpern Board Chair Isaacson Miller Founding Board Chair Emeritus Rockefeller Brothers Fund Visiting Scholar, University of Spencer Overton California Law School, Berkeley Ben Binswanger #e George Washington #e Case Foundation University School of Law O L: Christine Chen Wendy Puriefoy Robert Franklin APIA Vote Public Education Network Morehouse College Amy Hanauer Miles Rapoport David Skaggs Policy Matters Ohio President, Dēmos Colorado Department of Higher Education Sara Horowitz Amelia Warren Tyagi Working Today Business Talent Group Ernest Tollerson Metropolitan Transportation Eric Liu Ruth Wooden Authority Author and Educator Public Agenda Affiliations are listed for identification purposes only. Clarissa Martinez De Castro As with all Dēmos publications, the Coalition for Comprehensive views expressed in this report do not Immigration Reform necessarily reflect the views of the Dēmos Board of Trustees. Contents Introduction 1 Key Findings 1 Background: A Deregulated Credit Card Market 2 Uncovering the Facts About Who Pays the Most to Credit Card Companies 3 Going Inside the Credit Card Market: Different Borrowers, Different Prices 4 Four Types of Borrowers 4 Which Credit Card Holders Pay the Most? 5 Interest Rate by Income 6 Interest Rate by Race 6 Interest Rate by Gender 7 Borrower Beware: Penalties Are Likely 7 #e Late Payment Penalty 7 Universal Default 7 Who Pays the Penalty? 8 Policy Recommendations 8 Addressing Industry Practices and Enacting a Borrower’s Security Act 9 Technical Appendix 10 Endnotes 14 Related Resources 15 Introduction It has been nearly two decades since the credit card industry was deregulated with the promise of bringing greater competition and lower prices to consumers. In addition, technological advancements in underwriting, commonly referred to as risk-based pric- ing, have widened the market for credit cards to lower- and moderate-income consum- ers. #e result: In 2004, 35 percent of households with incomes below $10,000 had credit cards, while more than half of households with incomes between $10,000 and $24,999 had credit cards.1 While much is made of this democratization of credit, there is less public awareness and consumer knowledge about how the cost of credit varies across different segments of the population. Last year alone, households received nearly 8 billion credit card solicita- tions in their mailboxes.2 Often these solicitations promise teaser rates of 0 percent, or they might dangle the carrot of airline miles or cash-back rewards. But as our study uncovers, for about one-third of all cardholders, the carrot is not nearly as big as the stick. Today, almost all of the top 10 issuers of credit cards reserve the right to change the APR on the account at any time, for any reason.3 A single late pay- ment—even by as little as minutes—can result in penalty interest rates that average 24.51 percent. Under the shield of deregulation, credit card companies have shifted the cost of credit to individuals least able to afford it—using those profits to underwrite the free loans and bonus miles, rewards and other benefits enjoyed by higher income households. Our research found that four groups—low-income individuals, African Americans, La- tinos and single females—bear the brunt of the cost of credit card deregulation through excessive fees and high interest rates. KEY FINDINGS: • One-third of cardholders are paying interest rates in excess of 20 percent. • Cardholders with household incomes below $25,000 who have credit card bal- ances are two times more likely than households earning $50,000, and five times more likely than households earning over $100,000, to pay interest rates higher than 20 percent. • Cardholders with balances and household incomes between $25,000 and $50,000 are nearly two times as likely as households earning more than $50,000, and four times more likely than households earning over $100,000, to pay such rates. • Credit cardholders in the bottom two income quintiles with credit balances are more than twice as likely to pay penalty interest rates as those in the top two income quintiles. • African-American and Latino credit card holders with balances are more likely than whites to pay interest rates higher than 20 percent. Who Pays? 1 • Seven percent of white cardholders, 15 percent of African-American cardholders, and 13 percent of Latino cardholders pay interest rates higher than 20 percent. • Eleven percent of single women with credit card balances pay interest rates higher than 20 percent compared to 6 percent of single men with credit card balances. • In 2004, 21 percent of consumers reported missing or making a late payment. • Forty percent of African-American and 26 percent of Latino borrowers reported paying late or missing a payment. • Twenty-two percent of single women and more than 30 percent of borrowers with incomes less than $25,000 also reported making a late payment or missing a payment. While personal responsibility must be exercised by consumers, the lending industry must also exercise corporate responsibility. In the current regulatory environment, the bargaining power between lender and borrower is heavily tilted toward the lender. #e fact that the highest consumer costs are disproportionately borne by low-income fami- lies, African Americans, Latinos and single females raises additional moral questions and underscores the need to reexamine the public policy and regulatory framework re- lated to the credit card industry. Background: A Deregulated Credit Card Market #e credit card industry is measured on a scale of billions. Eight billion is the approxi- mate number of credit card offers Americans received in 2006. #e amount of debt owed on credit cards is $800 billion;4 $30 billion dollars is how much lenders profit each year.5 #e billion-dollar scale of the industry must be viewed in the context of a wave of deregulatory actions that began in the late 1970s with a Supreme Court decision. In Mar- quette National Bank of Minneapolis v. First Omaha Service Corp (hereafter “Marquette”) the Court ruled that Section 85 of the National Banking Act of 1864 allowed a national bank to charge its credit card customers the highest interest rate permitted in the bank’s home state—as opposed to the rate in the state where the customer resided.6 As a result, regional and national banks moved their operations to states with fewer protections for borrowers, such as South Dakota and Delaware, where there were no usury ceilings on credit card interest rates. In the mid-1990s, further deregulation of the credit card industry occurred as the result of another Supreme Court ruling. In Smiley v. Citibank, the Court ruled that fees could be defined as “interest” for the purposes of regulation and thus were subject to the rules set by Marquette. As such, the laws regulating fees were now to be determined by the state laws in which the bank was located. 2 Dēmos: A Network for Ideas & Action #e practical result of these two decisions is that state usury laws, which used to set limits or rules around interest rates and fees, are now toothless. Since Congress hasn’t stepped in to fill the void in consumer protection, there are no limits concerning when and how often card issuers can raise APRs or revise contract terms. In this deregulatory environment, the demand side of the market is split into two segments: consumers who pay low, competitive, regular APRs and the consumers who pay the high, delinquent, penalty APRs. Because of deregulation, each individual card issuer has virtually an un- limited ability to revise its APR at any time for any consumer. #erefore, firms are able to “price discriminate” by charging low APRs to consumers who pay their bills on time and charging high, penalty APRs to the consumers who miss a payment—or whose payment arrives and is processed just minutes after their daily cutoff time.
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