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Why a low cap cuts off credit
Credit card APRs are risk‑based: higher‑risk borrowers pay higher rates to cover expected defaults and the cost of unsecured, revolving credit.
If a cap is set well below current market rates (today’s average APR is around 21%, and has never fallen below roughly 12% in the data series), many accounts simply cannot be priced profitably at the capped rate.
Industry and research estimates suggest:
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A 10% federal cap could lead to roughly three‑quarters or more of open card accounts being closed or severely line‑cut.
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Analyses using Federal Reserve Survey of Consumer Finances data find that about two‑thirds of regular credit‑card borrowers—around 14 million families—would have their lines eliminated or reduced, with the harshest impact on higher‑risk segments.
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Nearly all accounts with scores below roughly 740 could be closed or heavily restricted under a 10% cap, implying 175–190 million cardholders losing effective access in some industry estimates.
Unintended consumer impacts
Once a cap bites, issuers respond on other margins:
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Reduced access and liquidity. Households that currently rely on cards for emergencies or cash‑flow gaps lose a key unsecured line; this is especially acute for subprime and near‑prime borrowers with fewer alternatives.
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Shift to higher‑cost products. Consumers who are cut off from cards may turn to payday loans, pawnbrokers, or informal “loan shark” credit, which often carry effective rates far above typical card APRs and weaker protections.
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Higher non‑interest pricing. To recoup lost interest revenue, banks can raise annual fees, penalty fees, and other charges, or increase required minimum balances in related deposit products, echoing what happened after the Durbin interchange cap in checking accounts.
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Weaker ability to rebuild credit. For consumers with thin or damaged files, losing a revolving bankcard makes it harder to generate positive trade‑line history and improve scores over time.
Illustration table: key channels
Design choices that matter
The severity of these consequences depends heavily on how a cap is structured:
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Level of the cap. A modest, non‑binding cap (well above typical risk‑based prices) has limited impact; a 10% cap is deeply binding in today’s environment and therefore highly disruptive.
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Scope and exemptions. Whether the cap applies to all cards, only to certain balances, or exempts small‑limit or secured products will change who loses access and which substitute products emerge.
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Complementary policies. Strong underwriting rules, transparent pricing, and targeted relief tools (e.g., hardship programs, income‑based repayment plans, or mandated affordable “safety‑net” card products) can address affordability without as blunt a price ceiling.
From a policy‑design standpoint, caps can look attractive politically but function like any other price control: if set too low, they generate shortages and push activity into less regulated, more expensive corners of the market.




