法規的變化與消費者金融上新關係的建構 是由出版商Packaged Facts在2010年12月所出版的。
這份英文市場調查報告書價格從美金3750起跳。
本報告，調查分析美國金融相關的各種法規與對消費者金融市場的影響，並彙整消費者&產業信用以及貸款的現狀、消費者的金融服務的使用與意識的調查等，由下列摘要形式闡述。
第1章 報告摘要
第2章 CARD Act：課題與策略
第3章 消費者透支保護：課題與策略
- Regulation E
- 透支收益・使用分析
- 2010上半年：透支收益・使用動向
- 收益牽引因子：高額度透支使用者
- FDIC提案：法規與預言手續費收入的下滑
- 前進策略
- 透支收益的減少・新策略應用，等
第4章 「Dodd-Frank Wall Street Reform」：課題・策略
- 「Durbin Amendment」與現金卡的交換手續費
- 「Bureau of Consumer Financial Protection」，等
第5章 宏觀經濟的影響・消費者的資產分析
- 消費者信賴感
- 失業率・GPD預測
- 好轉中的消費者的資產，等
第6章 消費者&產業的信用・貸款：表現動向
- 消費者&家庭貸款動向
- 信用卡動向
- 信用卡的貸款表現動向
- 信用卡的利息
- 卡片貸款餘額的擴大
- 存款動向，等
第7章 銀行的法規策略資料
- American Express
- JPMorgan Chase & Co.
- Bank of America
- Capital One Financial
- Discover Financial Services
- Wells Fargo
- U.S. Bancorp
- Citigroup
第8章 消費者的金融服務的使用與意識
- 對於個人金融・銀行的負面意識與市場機會
- 聚焦於年輕人族群
- 校園信用卡的4分之3為Bank America
- 畢業生組織與帳戶比例
- 18-20歲的學生：佔了所有學生的56%
- 關注於富裕層
- Wells Fargo：佔富裕層大幅比例，等
附錄
Abstract
Driven by confluence of recession-induced changes, 2010 brings a perfect storm
to the card industry: deteriorated credit quality, consumer credit pullback,
shrinking credit card portfolios, and sweeping regulatory change. The CARD Act
and the Dodd-Frank Act are reshaping both ends of the consumer banking
relationship, as industry participants retool their consumer card and banking
strategies, and as consumers adapt their banking and card preferences,
attitudes and usage patterns as the recession continues.
Packaged Facts' Regulatory Change and The New Consumer Card and Banking
Relationship is necessary reading for industry participants navigating the
effect these sweeping regulations are having on their credit card, debit card,
gift card and consumer banking strategies. In emphasizing a trend-forward
philosophy, the report also assists in viewing the impact of these regulations
into 2011 and 2012.
The report breaks down relevant regulations and their impact on the market, in
part by trending important industry metrics (such as interest rates, fees, and
penalties) in detail. To help gauge the effect and future ramifications on the
consumer, Packaged Facts conducts “Regulatory Impact and Trend
Forecasting” on three groups significantly affected by the regulations:
Echo Boomers, The Affluent, and The Debt-Burdened. “Regulatory Response
and Strategy Profiles” of the top 10 card issuers help gauge industry
responses and strategies.
Table of Contents
Chapter 1: Executive Summary
- The CARD Act: Challenges and Strategies
- Card Act - Stage I - August 2009
- Notice and mailing requirements
- Card Act - Stage II - February 2010
- Eliminating harmful practices and increasing transparency
- Card Act - Stage III - August 2010
- Disproportionate penalties and rate increase reevaluation
- Fee must be reasonable and proportional
- Federal Reserve moves to amend regulations and provide clarification
- Ramifications of the CARD Act
- Cost to banks in the billions
- “Reasonable and proportional” application still looms
- Strategies to make up the difference
- Penalty and Transaction Fee Trends
- Consumer Overdraft Protection: Challenges & Strategies
- The Key Provision: Regulation E
- What is it?
- Amendments and their effect
- Overdraft Revenue & Usage Analysis
- FDIC Study of Bank Overdraft Programs
- Earnings estimates
- Revenue estimates
- Revenue drivers
- 90% of NSF fees accrued from customers with 5+ NSF transactions per
year
- FDIC proposal foretells more regulation, reduced fee income
- Supervisory action threatened
- Steering high-frequency overdraft users a no-no - and we' re watching
- Opt-out of non-ATM and non-POS debit transactions?
- High-to-low processing history? Prepare to hide
- Wells Fargo litigation sets precedent for additional litigation
- For how much could the industry be on the hook?
- $203 million in restitution to Californians for three years of
high-to-low posting
- Strategies going forward
- Keep trying to get them to opt in!
- Or engage in “revenue expansion”
- Overdraft revenue fallout & evolving strategy applications
- Q3 2010 tale of the tape
- Dodd-Frank Wall Street Reform: Challenges and Strategies 13
- The Durbin Amendment & Debit Interchange
- Actual cost incurred
- Merchants allowed to set minimum amounts and incent use of cash
- Woe to debit interchange!
- We believe commercial banking combined interchange exceeds $70 billion
- Q3 2010 combined card interchange among top 10 banks: $17 billion
- Q3 2010 debit interchange tops $2 billion at Bank of America alone
- Going forward
- Sue the government!
- Segue into contactless
- Or buy stock in PIN debit processors
- Bureau of Consumer Financial Protection
- What is it and what is it supposed to do?
- What is the scope of its authority?
- Broad rule-making authority
- Broad enforcement authority
- Macroeconomic Influences & Consumer Wealth Analysis
- Consumer confidence helps put brakes on spending
- Unemployment picture stabilizes
- Unemployment and GPD forecast
- Consumer Wealth on the Mend
- Household wealth repair
- Case-Shiller and FOMC housing pessimism
- Householder equity comes off its bottom
- Stock equity trends
- Consumer & Industry Credit and Loan Performance Trends 20
- Saving more + paying down debt = a healthy consumer
- Chipping away at the debt burden
- Consumers unburden themselves of debt
- Debt service ratios peak at onset of 2008 and decline thereafter
- Consumer & Household Loan Trends
- Credit Card Trends
- Revolving credit declines
- Credit card loan performance trends
- Credit card interest income a saving grace
- Card lending policies final loosen a bit
- Unused credit line culling coming to a close?
- Credit card tightening starting to loosen
- Card Loans Outstanding Growth Mirrored By Purchase Volume Gains
- Visa leads MasterCard in credit and debit purchase volume growth
- Big Six Issuers each grow purchase volume
- Deposit Trends
- Bank of America leads total domestic deposits
- Banking Institution Regulatory Strategy Profiles
- American Express
- Response to Credit CARD Act
- Regulatory Impact
- CARD Act impact
- Durbin Amendment impact
- U.S. growth trends
- JPMorgan Chase & Co.
- Chase' s take on regulatory reform
- Card Services
- Response to CARD Act
- Adjust intro rates, promo rates, and contract rates
- Retail Banking
- Reg E impact
- More than 26 million checking accounts - 1,300 per banker
- Bank of America
- Company Overview
- Global Card Services segment
- CARD Act Response
- $1 billion CARD Act impact
- Deposits segment
- Reg E strategy and impact
- $1 billion after-tax!
- Overdraft strategy: high-to-low ringing in Bank of America' s ears?
- eBanking intended to drive down costs
- Looking ahead: Not an overdraft fee; a convenience fee
- $10 billion Durbin Amendment impact
- Capital One Financial
- Card Act and Rewards
- Discover Financial Services
- Company overview
- Network and Card Initiatives
- Student loans diversify company away from plastic
- And toward cross-selling opportunity
- Wells Fargo
- Cross-selling champion
- Response to Credit CARD Act
- Consumer Banking
- Reg E impact: $800 million and counting
- High-to-low reaches a low point
- U.S. Bancorp
- Consumer Banking
- Payment Services
- Reg E, CARD Act and Durbin Impact
- Revised overdraft policy
- Citigroup
- Cards and CARD Act
- Simplicity in checking
- Consumer Financial Services Usage & Attitudes
- Negative attitudes provide opportunity
- Credit card engagement falls; high-frequency use increases share
- Balance payment trends relatively unchanged
- Focus on young adults
- Table 1-1: Echo Boom Generation, % of Population, 2006-2015
- Protections for young people not reflected in issuer terms and conditions
- Campus credit card promotional agreements monitored
- Three-quarters of campus spend from Bank America
- Alumni organizations & foundations generate disproportionate account
share
- Table 1-2: Educational Institutions and Organizations, Card
Agreements, Selected Metrics, 2009
- Students age 18-20 comprise 56% of all students
- Table 1-3: Full-Time and Part-Time Students, By Age, 2010
- Focus on the affluent
- Primary banking relationships provide the key to success
- Wells Fargo commands mass affluent share
Chapter 2: The CARD Act: Challenges and Strategies
- Card Act - Stage I - August 2009
- Notice and mailing requirements
- Card Act - Stage II - February 2010
- Eliminating harmful practices and increasing transparency
- Card Act - Stage III - August 2010
- Disproportionate penalties and rate increase reevaluation
- Fee must be reasonable and proportional
- Federal Reserve moves to amend regulations and provide clarification
- Consumer protections enhanced
- Promotions waiving interest & offering reduced rate afforded same
protections
- Fee cap applies to fees charged before and after the account is opened
- Individual' s independent income must be considered
- Ramifications of the CARD Act
- Cost to banks in the billions
- “Reasonable and proportional” application still looms
- Rewards on the block?
- Rewards-related penalties crop up
- Strategies to make up the difference
- Penalty and Transaction Fee Trends
- Penalty interest rates increase
- Undisclosed penalty APRs on almost 50% of cards
- Late fees remain ubiquitous while overlimit fees decline
- Penalty interest rates increase and are still widely used
- Cure period disclosures
- Transaction surcharge fees remain common
- Cash advance fee and balance transfer rates rise
- Annual fee amounts spike
Chapter 3: Consumer Overdraft Protection: Challenges & Strategies
- The Key Provision: Regulation E
- What is it?
- Amendments and their effect
- Getting more specific
- No fees for ATM and one-time debit card overdrafts without opt-in
- No exceptions
- Written documentation
- Does not apply to check, ACH, and recurring debit card transactions
- Overdraft Revenue & Usage Analysis
- FDIC Study of Bank Overdraft Programs
- 4 in 5 automated programs allow ATM and POS overdrafts
- Customers informed afterward
- High-to-low ordering practices conducted by majority of large banks
- Earnings estimates
- Revenue estimates
- Revenue drivers
- 90% of NSF fees accrued from customers with 5+ NSF transactions per year
- H1 2010 Overdraft Revenue and Usage Trends
- Table 3-1: U.S. Banking Overdraft Revenue, 2005-2011 ($ billions)
- Opt-in trends
- Revenue drivers: high-frequency overdraft users
- Study asserts 60% and 80% opt-in rate
- We' re more pessimistic
- Packaged Facts Foresees More Trouble Ahead
- FDIC proposal foretells more regulation, reduced fee income
- Limits on number of overdrafts, daily fee accrual and high-to-low
processing
- Supervisory action threatened
- Steering high-frequency overdraft users a no-no - and we' re watching
- Opt-out of non-ATM and non-POS debit transactions?
- Wanted: Responsible transaction account and small-dollar loan program
innovation!
- Outcry, outcry!
- Scrutinize? Take supervisory action? Industry says this goes too far
- Set expectations, but don' t regulate them
- Consumers and consumer groups want it to go further
- Consumer advocacy groups circle the wagons
- Set concrete limits - and enforce them!
- High-to-low processing history? Prepare to hide
- Wells Fargo litigation sets precedent for additional litigation
- For how much could the industry be on the hook?
- $203 million in restitution to Californians for three years of
high-to-low posting
- 11% of overdraft revenue
- The details: High-to-low posting under legal fire
- Commingling and deployment of the shadow line
- Legal conclusion: gouging & profiteering drove overdraft program changes
- Strategies going forward
- Keep trying to get them to opt in!
- Or engage in “revenue expansion”
- Table 3-2: Fiserv revenue realization estimates, overdraft mitigation
strategies
- New deposit products
- Short-term liquidity solutions
- Cross-sell, loyalty and retention products
- Predictive Analytics
- Overdraft revenue fallout & evolving strategy applications
- Q3 2010 mitigation: tale of the tape
- Provident & National Penn succeed with high-frequency users
- PNC, Regions and Fifth Third losses range from $5 million to $50 million
- Bank of America new account opt-in rate at 40%
- SunTrust eliminates fees on transactions valued at less than $5
- First Financial Bancorp reports no customer attrition
- “Grace period” trades fee income for market share & customer
satisfaction
- Customization + cross-selling = revenue
- Compass Bancshares customizes with “free” checking and
“premium” add-ins
- KeyCorp gives layered “Key Coverage” - for $10 a month
- Proactive communication + courtesy = fees and higher customer
satisfaction
- United Heritage Credit Union: “Courtesy Pay” to
“help” and provide “options”
- A friendly reminder from mobile banking . .
- . . . To incentivize use of overdraft protection
Chapter 4: Dodd-Frank Wall Street Reform: Challenges and Strategies
- The Durbin Amendment & Debit Interchange
- Bottom line
- Fees
- Reasonable and proportional
- Actual cost incurred
- Who' s exempt?
- Merchants allowed to set minimum amounts and incent use of cash
- Woe to debit interchange!
- $20 billion in the balance?
- We believe commercial banking combined interchange exceeds $70 billion
- Q3 2010 combined card interchange among top 10 banks: $17 billion
- Q3 2010 debit interchange tops $2 billion at Bank of America alone
- Table 4-1: Top 10 Banks, By Bank Card and Credit Card Interchange Fee
Income, 2010
- Which helps explain Bank of America' s $10 billion goodwill write-off
- Going forward
- Sue the government!
- Segue into contactless
- Or buy stock in PIN debit processors
- Bureau of Consumer Financial Protection
- What is it and what is it supposed to do?
- To what or who does the BCFP report?
- What is its structure?
- What is the scope of its authority?
- Consolidation and enhancement of consumer protection authority
- Who is exempt?
- Broad rule-making authority
- Broad enforcement authority
Chapter 5: Macroeconomic Influences & Consumer Wealth Analysis
- Consumer confidence helps put brakes on spending
- Current perceptions of business conditions, job prospects darken
- Expectations Index dips as job prospect optimism dims
- Unemployment picture stabilizes
- Figure 5-1: Unemployment Rate and Consumer Confidence, 2007-2010
- Unemployment and GPD forecast
- Adjusted projections
- Table 5-1: Unemployment and GDP Forecast, 2010-2012
- Consumer Wealth on the Mend
- Household wealth repair
- Table 5-2: Household Net Worth, 2005-2010 (in trillions of $)
- Case-Shiller and FOMC housing pessimism
- Bottom line: recent growth, but weakening trends
- Householder equity comes off its bottom
- Table 5-3: Household owners' equity in real estate, 2004-2010
- Stock equity trends
- Bottom line analysis
- Figure 5-2: Wealth Effect: Wilshire 5000 and Case Shiller Index,
2007-2010
Chapter 6: Consumer & Industry Credit and Loan Performance Trends
- Saving more + paying down debt = a healthy consumer
- Chipping away at the debt burden
- Consumers unburden themselves of debt
- Bottom line
- Figure 6-1: Consumer Debt Burden, 2000-2010
- Debt service ratios peak at onset of 2008 and decline thereafter
- Analysis
- Figure 6-2: Savings Rate & Debt Service Ratio, 2007-2010
- Consumer & Household Loan Trends
- Table 6-1: Loans Outstanding, by Loan Type, FDIC-Insured Institutions,
2007-2010 (in billions of dollars)
- Mortgage loan performance trends
- Figure 6-3: Loan Performance, Closed-End First Lien 1-4 Family
Residential Mortgages, 2007-2010
- Credit Card Trends
- Revolving credit trends in focus
- Figure 6-4: Consumer Revolving and Non-Revolving Debt Trends, 2004-2010
- Figure 6-5: Consumer Revolving and Non-Revolving Debt Trends, %
Change, 2004-2010
- Credit card loan performance trends
- Figure 6-6: Loan Performance, Credit Cards, 2007-2010
- Table 6-2: Credit Card Loans Outstanding & Unused Credit Card Lines,
2007-2010 (in billions of dollars)
- Table 6-3: Top 15 FDIC-Insured Institutions, Credit Card Loan
Receivables, Q3 2009 vs. Q2 2010 (in billions of dollars)
- Figure 6-7: 30-Day Monthly Delinquency Rates, Top Six Card Issuers, %
Change, 2009-2010
- Credit card interest rates increase while banks' borrowing costs decrease
- Federal funds target rate at historical lows
- Profit margins breathe easier
- Figure 6-8: Credit Card Interest Rate & Federal Funds Rate Trends,
2004-2010
- Credit card interest income a saving grace
- Figure 6-9: Top 10 Banks, By Credit Card Interest Income, 2010
- Card lending policies final loosen a bit
- Unused credit line culling coming to a close?
- Credit card tightening starting to loosen
- Figure 6-10: Credit Card Loan Tightening, Top 100 Banks, Q1 2007 to Q4
2010
- Card Loans Outstanding Growth Mirrored By Purchase Volume Gains
- Visa leads MasterCard in credit and debit purchase volume growth
- Figure 6-11: Quarterly Purchase Volume, Visa and MasterCard, Credit
and Debit Cards, 2009-2010
- Big Six Issuers each grow purchase volume
- Figure 6-12: Quarterly Purchase Volume, Big Six Issuers, Credit Cards,
2009-2010
- Deposit Trends
- Table 6-4: Domestic Deposits, by Type of Deposit, 2007-2010 (in billions
of dollars)
- Bank of America leads total domestic deposits
- Table 6-5: Top 15 Commercial Banks & Savings Institutions, Total
Number of Offices and Domestic Deposits, 2007 vs. 2010
Chapter 7: Banking Institution Regulatory Strategy Profiles
- American Express
- Value Proposition
- Table 7-1: 2008 Worldwide Cardholder Spend, American Express, Visa, &
MasterCard
- Company overview
- Response to Credit CARD Act
- American Express well-situated to take advantage of frugality trend
- Regulatory Impact
- CARD Act impact
- Durbin Amendment impact
- Sales and Card Growth
- Worldwide assessment
- Table 7-2: American Express Card Billed Business, Discount Revenue,
Net Card Fees, 2007-Q2 2010 (in billions of $)
- Table 7-3: American Express Discount Rate, Card Spend, & Fee per Card,
2005-Q2 2010
- U.S. growth trends
- Table 7-4: American Express U.S. Region Billed Business & Cards in
Force, 2005-2009
- JPMorgan Chase & Co.
- Chase' s take on regulatory reform
- Card Services: Summary Overview
- Response to CARD Act
- Adjust intro rates, promo rates, and contract rates
- Table 7-5: JPMorgan Chase Card Services, Interest Rate Offerings
Change, 2008-2009
- JPMorgan Chase Card Services by the Numbers
- Down, down, down: cards, transactions and volume
- Retail Banking: Summary Overview
- Reg E impact
- More than 26 million checking accounts - 1,300 per banker
- Table 7-6: JPMorgan Chase Retail Banking, Retail Footprint Metrics,
2005-2010
- Table 7-7: JPMorgan Chase Retail Banking, Household Product Usage, By
Type, 2005-2010
- Bank of America
- Company Overview
- Global Card Services segment
- Card Act Response
- $1 billion CARD Act impact
- Card Act and Rewards
- Deposits segment
- Reg E strategy and impact
- $1 billion after-tax!
- Overdraft strategy: high-to-low ringing in Bank of America' s ears?
- eBanking intended to drive down costs
- ATM emergency cash tied to payroll card - and a $35 fee
- And emergency cash tied to credit card
- And emergency cash tied to an ATM!
- Looking ahead: Not an overdraft fee; a convenience fee
- $10 billion Durbin Amendment impact
- Bank of America: Key Metrics
- Table 7-8: Bank of America, Selected Credit Card and Consumer Banking
Metrics, 2008-09
- Table 7-9: Bank of America Demographics: A Tale of the Tape, 2010
- Capital One Financial
- 2008-2010 trends
- Card Act Response
- Card Act and Rewards
- Capital One: Key Metrics
- Table 7-10: Capital One, Key Credit Card Metrics, 2007-2009 (in
millions, except ratios and where otherwise noted)
- Discover Financial Services
- Company overview
- Network and Card Initiatives
- Response to Credit CARD Act
- Student loans diversify company away from plastic
- And toward cross-selling opportunity
- Response to Recession
- Table 7-11: Discover, Key Credit Card Metrics, 2007-2009 (in millions,
except ratios and where otherwise noted)
- Wells Fargo
- Company overview
- Cross-selling champion
- Response to Credit CARD Act
- Consumer Banking
- Reg E impact: $800 million and counting
- High-to-low reaches a low point
- Wells Fargo: Key Metrics
- Table 7-12: Wells Fargo, Key Credit Card Metrics, 2007-2009 (in
millions, except ratios and where otherwise noted)
- Table 7-13: Wells Fargo, Core Deposits, by Type, Q1 2009-Q2 2010 .147
- Table 7-14: Wells Fargo, Retail Banking Metrics, 2010
- U.S. Bancorp
- Consumer Banking
- Payment Services
- Reg E, CARD Act and Durbin Impact
- Revised overdraft policy
- Citigroup
- Cards and CARD Act
- Simplicity in checking
Chapter 8: Consumer Financial Services Usage & Attitudes Trends
- Negative personal finance and banking attitudes provide opportunity
- Table 8-1: Attitudes about Personal Finance, 2005-2010
- Table 8-2: Consumer Banking Products Usage, by Type, 2005-2010
- Table 8-3: Consumer Loans, by Type, 2005-2010
- Table 8-4: Consumer Investments, by Type, 2005-2010
- Table 8-5: Credit Card Engagement, 2005-2010
- Portion of paid balances
- Table 8-6: Credit Card Monthly Payments, Portion Paid, All Cards,
2005-2010
- Focus on young adults
- Table 8-7: Echo Boom Generation, % of Population, 2006-2015
- Protections for young people not reflected in issuer terms and conditions
- Campus credit card promotional agreements monitored
- Three-quarters of campus spend from Bank America
- Alumni organizations & foundations generate disproportionate account share
- Table 8-8: Educational Institutions and Organizations, Card Agreements,
Selected Metrics, 2009
- Students age 18-20 comprise 56% of all students
- Table 8-9: Full-Time and Part-Time Students, By Age, 2010
- Focus on the affluent
- Table 8-10: Household Income, by Income Bracket, 2008
- Primary banking relationships provide the key to success
- Wells Fargo commands mass affluent share
- Table 8-11: Affluent Consumers, Primary Banking Relationship, by HH
Income Segments
Chapter Appendix: Trended Credit Card Balances, Portions Paid
- Table 8-12: Credit Card Monthly Payments, Portion Paid, American Express,
2005-2010
- Table 8-13: Credit Card Monthly Payments, Portion Paid, Discover, 2005-2010
- Table 8-14: Credit Card Monthly Payments, Portion Paid, MasterCard,
2005-2010
- Table 8-15: Credit Card Monthly Payments, Portion Paid, Visa, 2005-2010
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