Facts Matter: Reading the CARD Act Report in Context
The Credit Card Accountability Responsibility and Disclosure (CARD) Act requires the Consumer Financial Protection Bureau (CFPB) to submit a biennial report to Congress assessing the state of the consumer credit card market. For more than a decade, these reports have served an important empirical function – providing a shared factual baseline for policymakers, consumer advocates, and industry participants alike.
The CFPB’s 2025 Consumer Credit Card Market Report represents a noticeable shift in tone from some prior iterations. Specifically the CARD Act Reports that were released under the prior Biden-Chopra Administration often had press releases and conclusions not supported by the underlying data. The Biden-Chopra CFPB would then leverage the report to push new narratives, including stretching its mandate to question the profitability of market participants and introducing new European regulatory frameworks.
Fortunately, unlike the prior Administration’s reports, the 2025 Report was released without inflammatory press campaigns and much of its analysis is presented in a more technical, data-driven manner. That restraint is welcome.
At the same time, how data are framed and which connections are drawn matters. In several areas, the 2025 Report continues analytical frameworks introduced under former CFPB Director Rohit Chopra, and in others it presents headline statistics that could easily be misread without additional context. Indeed, former CFPB Director Chopra himself underscored the stakes of interpretation when he publicly endorsed the Report on social media, describing its findings as relevant to addressing the “high cost of living.”
The data in the 2025 Report are largely objective and empirical. But, particularly in its Executive Summary, there are questions about how the data is framed.
The Executive Summary highlights that 15 percent of general-purpose cardholders and 20 percent of private-label cardholders made only the minimum payment in 2024, levels described as the highest observed since at least 2015. Placed alongside statistics showing record purchase volume, rising balances, and higher interest charges, a casual reader – particularly one relying primarily on the Executive Summary – could reasonably come away with the impression that the credit card market is tilting in a troubling direction. Read together, those headline figures risk painting a picture not only of individual consumers increasingly unable to manage their credit card debt, but of a marketplace that is fundamentally failing to function as intended.
But the Report could have done more to connect the dots – or at least acknowledge alternative, equally plausible narratives supported by the same data – to reduce the risk of misunderstanding.
This piece is not a “rebuttal” to the broader CARD Act Report, but it does flag two potential concerns regarding how its data could be interpreted, particularly by casual readers. In doing so, we flag a narrower quibble with the Report’s analytical approach and then turn to a more consequential issue: how the Report’s discussion of minimum payments may inadvertently fuel confusion about the role credit cards play in household affordability.
A Quibble: The Report Continues to Bypass Established Antitrust Measures in Favor of Novel Theories
The 2025 CARD Act Report continues the CFPB’s examination of market competitiveness, an analytical focus introduced under former CFPB Director Chopra as part of his broader effort to argue that a lack of competition in the credit card market justified government intervention in pricing. The Report notes that approximately 3,700 financial institutions offered credit cards in 2024 and highlights that the ten largest issuers hold roughly 84 percent of outstanding balances – a figure that has remained relatively stable since 2016.
What is notably absent from this discussion is any reference to traditional measures of market concentration, such as the Herfindahl-Hirschman Index (HHI) or revenue concentration, which are routinely used by antitrust and banking regulators to assess competitive conditions. To be clear, under current Department of Justice and Federal Trade Commission guidelines, the industry’s HHI does not meet the thresholds typically associated with a “highly concentrated” market.
If the CFPB believes traditional concentration measures fail to capture meaningful aspects of competition in the credit card market, that may be a reasonable hypothesis –but one that should be acknowledged and explained. At a minimum, readers would benefit from seeing those benchmarks cited and then contrasted with alternative, “hipster-antitrust” approaches, rather than bypassed altogether.
Moreover, the Report contains – within its own data – more dynamic indicators of competition that better reflect how consumers experience the market in practice. Issuers sent more than 400 million direct mail solicitations each month in 2023 and 2024, competing aggressively across credit tiers. Nearly 30 percent of those offers targeted consumers with below-prime credit scores, underscoring that competition is not confined to superprime segments.
Perhaps most tellingly, consumers transferred approximately $60 billion in outstanding balances in 2024 alone. That is comparable in scale to the sum of some of the largest portfolio transactions in the industry’s history, including the Apple Card ($20 billion, 2025); the Costco Credit Card ($10.5B, 2016); Wal-Mart Credit Card ($8.5B, 2024); Gap Inc. Portfolio (including Gap, Old Navy, Athleta, and Banana Republic) ($3.8B, 2021); and Target RedCard ($5.7B, 2013) portfolios. The amount of balance transfers that moved from one issuer to another is greater than the total holdings of each but the top six credit card issuers moving in full each and every year.
That level of balance transfer activity demonstrates that competition does not end once an account is opened. Issuers must continually compete to retain customers – often by offering lower rates, promotional terms, or enhanced features – lest balances migrate elsewhere.
Taken together, these dynamics point to a market characterized by constant solicitation, high churn, and active consumer choice. Concentration ratios may describe where balances sit at a moment in time, but they do not fully capture the intensity of competition consumers experience day to day.
Minimum Payments: What the Executive Summary Doesn't Tell You About Repayment Behavior
More importantly, though, the most consequential interpretive issue in the 2025 Report concerns its discussion of minimum payments.
Read in isolation, the Executive Summary’s emphasis on minimum-payment incidence – paired with record spending, higher balances, and rising interest charges – can easily be interpreted as evidence of mounting consumer distress caused by their use of credit cards. That framing risks suggesting not just household-level strain, but a credit card market that is no longer functioning as intended.
That inference is contradicted by CARD Act Report data that is not included in its Executive Summary. Without this additional context, the Executive Summary’s framing invites readers to conflate higher usage, higher balances, and the incidence of minimum payments with systemic distress that’s specific to the card market, rather than considering alternative explanations – such as consumers using credit cards as short-term liquidity tools to manage expense shocks outside of the card market, while still demonstrating historically strong repayment behavior on an annual basis.
The key piece of context lies, waiting to be found, in the Report’s footnote 119, which explains that the minimum payment statistic reflects accounts that made a minimum payment at least once during the year, not accounts that consistently paid only the minimum month after month.
When viewed alongside the Report’s broader repayment data, a different picture emerges. The top part of Figure 44, below, shows that if you expand the aperture to look at annual data, the share of consumers paying their balances in full reached 43 percent. This is the highest level observed outside the 2021–22 stimulus period.
Likewise, Figure 42, below, shows that consumers paid a higher share of principal in 2023 and 2024 than in any pre-pandemic year (37 percent). Indeed, CFPB’s data indicates that this improvement in payment behavior is at least partially attributable to industry action, because the Report separately notes that industry has steadily raised minimum payment requirements so that in 2024, “the most common floor was $40, a $15 increase since 2015."
Neither of these figures are included in the Executive Summary. But taken together (along with Section 4.2’s data on charge-offs and delinquencies), these trends suggest that consumers are managing credit card debt about as well as they have at any point since the CFPB began collecting comparable data in 2015.
At the same time, the increase in accounts making at least one minimum payment may reflect something else entirely: consumers using credit cards for short-term liquidity, smoothing expense shocks that arise elsewhere in household budgets, while still repaying balances over time. In that light, minimum payment flexibility looks less like a sign of distress and more like a feature of how credit cards function as financial shock absorbers.
This distinction matters. As former CFPB Director Chopra’s tweet indicates, financial products like credit cards are often framed as culprits in an “affordability crisis.” But the data in the 2025 Report are equally consistent with a different narrative: consumers are relying on credit cards to manage affordability challenges driven by far larger costs elsewhere in their lives, including housing (where mortgages and rents increasingly take up 30 percent of incomes), health care (where the monthly price of health insurance is now nearly $500), child care (where half parents spend at least 50 percent on care as they do housing), and education (where the cost of tuition at public colleges has risen 177 percent since the 1970s).
The Bottom Line
The 2025 CARD Act Report contains the data needed to tell a fuller story. Connecting those dots – or at least acknowledging that alternative interpretations are supported by the same evidence – would help ensure the Report continues to fulfill its core purpose: informing policy through neutral, empirical analysis rather than shaping it through implication.
