Weekly Wisdom: Financials Remain Attractive Among Interest Cap Volatility

Interest Rate Cap Rhetoric is Creating Headlines, Not Lasting Risk

Over the weekend, President Trump called for a one-year cap of 10% on credit card interest rates, generating volatility across consumer lending stocks, particularly among card-focused issuers. While in theory, a hard cap could pressure card yields, reduce credit availability for higher-risk borrowers, and alter consumer behavior. However, we believe the real impact will be limited compared to current market sentiment. Given the difficulty of implementation, combined with the competitive nature of the market, the overwhelmingly prime credit mix at most large banks, and multiple levers issuers can deploy, such as higher fees, lower rewards costs, and tightening underwriting, we expect any effect on earnings to be modest.

Legislative and Practical Barriers Remain High

In practice, legal and practical hurdles make implementation uncertain. Legal authority for such a move is unclear, and any attempt to impose a hard cap via executive order would almost certainly face immediate court challenges and delays. Formal rulemaking through regulatory agencies would take months to complete, far too long to deliver relief before the midterms. In addition, previous efforts to legislate similar proposed interest caps in 2025 and again in 2019 failed amid strong industry and political opposition, illustrating how difficult it is to enforce even with bipartisan support. Analysts have highlighted hesitance in implementation with a Bloomberg report stating a mere 30% probability of success by 2026.¹ Taken together, these factors make it highly unlikely that the current proposal, as framed by President Trump, will translate into meaningful policy in the near term.

A Competitive Market Limits the Case for Intervention

The credit card industry remains highly competitive, with consumers able to choose among cards, installment loans, unsecured and secured credit lines, and mortgages. There is little evidence of market failure. A May 2025 New York Fed study showed that only 46% of cardholders carried a balance at least once during the past year, while less than 20% of available credit card lines are utilized.² A broad rate cap could therefore eliminate interest-free grace periods, raise minimum payments, and restrict access to credit for lower-FICO borrowers, outcomes that previously fueled opposition to the five-year proposal.

Credit Quality and Diversification Limit Downside Risk

From a credit standpoint, large banks remain overwhelmingly positioned toward prime borrowers. Bank of America reports an average FICO score of 777, with only 12% of borrowers below 660.³ JPMorgan disclosed a weighted-average FICO score of 774⁴, while Wells Fargo’s largest segment of credit card balances is held by borrowers with FICO scores above 740.⁵ Capital One remains the exception, with 27% of its domestic card portfolio carrying FICO scores of 660 or below, though that exposure has declined following the Discover acquisition.⁶ At the same time, credit card income represents a modest share of earnings for diversified banks, accounting for 6.2% of net interest income at JPMorgan, 10.5% at Bank of America, and 12.4% at Wells Fargo.⁷ These factors leave banks well-positioned to absorb any potential impact from a rate cap, making meaningful earnings disruption unlikely.

Financials Have Multiple Offsets to Protect Earnings

Even in a hypothetical scenario where pricing pressure were introduced, large financial institutions have numerous levers to protect profitability. These include higher annual and ancillary fees, reduced rewards and loyalty costs, tighter underwriting standards, and lower operating expenses tied to marketing and customer acquisition. Improving credit trends provide an additional offset, as delinquencies, down -13 bps year-over-year, and net charge-offs, down -43 bps year-over-year, have continued to track favorably relative to historical norms, supporting expectations for lower credit costs into 2026.⁸

Taken together, we believe concerns around a credit card interest rate cap are overstated. Past efforts to impose a multi-year cap have failed, and the current proposal faces similar structural, legal, and political hurdles. With strong credit quality, improving loss trends, diversified earnings streams, and multiple operational offsets, financial institutions are well-positioned to manage through the current policy noise. We remain constructive and bullish on the financial sector and view recent volatility as an opportunity rather than a change in underlying fundamentals.

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1 BI Policy Watch: Credit-Care Rate Cap’s Long Odds, as of December 2025
2 Federal Reserve Bank of NY, as of May 2025
3 Bank of America, as of November 2025
4 JP Morgan, as of May 2025
5 Wells Fargo, as of October 2025
6 Capital One, as of October 2025
7 Bloomberg, as of December 2025
8 Barclays, as of October 2025