WASHINGTON—Calling federal scrutiny of credit card rewards “a solution in search of a problem,” the American Bankers Association is urging the CFPB and the Department of Transportation to roll back a series of actions it says improperly target popular rewards programs and risk undermining their future.
In a letter to Acting CFPB Director Russell Vought, ABA President and CEO Rob Nichols asked the Bureau to withdraw its December 2024 rewards circular, remove a CFPB-backed statement supporting DOT’s inquiry into airline rewards, and take down a 2024 “issue spotlight” that flagged concerns with rewards products.
ABA argued that the CFPB’s recent focus on rewards programs rests on “unfounded concerns” and mischaracterizes a market that, in the group’s view, is working well for consumers. Citing the Bureau’s own data, ABA said complaints about credit card rewards account for just 0.09% of all consumer complaints submitted to the CFPB—far too low, it contends, to justify labeling rewards as a systemic problem. The letter notes that issuers respond promptly to nearly all such complaints and often provide monetary or non-monetary relief.
The association also defended rewards as broadly accessible and valuable, particularly for households seeking savings, travel benefits, or flexible redemption options. According to ABA, competition among issuers has driven a wide array of features—from cashback and points to exclusive discounts and promotions—that increase purchasing power, build loyalty, and deliver “significant value” to cardholders across income levels. The group further argued that merchants benefit from rewards-driven card spending, which it said typically exceeds cash purchases while reducing cash-handling costs and improving transaction security.
Beyond the policy debate, ABA’s letter zeroed in on process, asserting that the CFPB’s rewards circular functions as a “legislative rule” that should have gone through formal notice-and-comment rulemaking under the Administrative Procedure Act. By issuing what it calls de facto rules in the guise of guidance, ABA said, the Bureau has created confusion, deprived industry of fair notice, and potentially exceeded its statutory authority—especially in areas touching on unfair, deceptive, or abusive acts or practices.
For those reasons, ABA urged the CFPB to rescind the rewards circular, remove the related press releases and issue spotlight, and distance itself from the now-inactive Credit Card Comparison Tool that featured in the Bureau’s messaging. Leaving those documents in place, the association warned, risks chilling legitimate rewards offerings that “do not present consumer protection risks but, on the contrary, benefit consumers of all types.”