Private Information and Price Regulation in the US Credit Card Market

The 2009 CARD Act limited credit card lenders' ability to raise borrowers' interest rates on the basis of new information. Pricing became less responsive to public and private signals of borrowers' risk and demand characteristics, and price dispersion fell by one-third. I estimate the efficiency and distributional effects of this shift toward more pooled pricing. Prices fell for high-risk and price-inelastic consumers, but prices rose elsewhere in the market and newly exceeded willingness to pay for over 30% of the safest subprime borrowers. On net, average traded prices fell and consumer surplus rose at all credit scores. Higher consumer surplus was partly driven by a fall in lender profits, and partly by the Act's insurance value to borrowers who could retain favorable pricing after adverse changes to their default risk. The relatively high level of pre-CARD-Act markups was crucial for realizing these surplus gains.