| Candidate Information | | Title | Credit Card Office Clerk | | Target Location | US-FL-St. Petersburg |
| | 20,000+ Fresh Resumes Monthly | |
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Click here or scroll down to respond to this candidateCONSUMER FINANCIAL PROTECTION BUREAU OCTOBER 2023The Consumer Credit CardMarket2 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT Table of contentsTable of contents 2 Executive summary 4 1. Introduction 8 1.1 Report mandate 8 1.2 Data sources 10 1.3 Definitions 12 2. Market dynamics 15 2.1 Cardholders 15 2.2 Issuers 18 2.3 Co-brand partners 25 2.4 Networks 27 2.5 Debt collectors 28 3. Use of credit 31 3.1 Purchase volume 31 3.2 Debt levels 33 3.3 Repayment 36 3.4 Non-payment 45 4. Cost of credit 48 4.1 Total cost of credit 49 4.2 Interest 52 4.3 Fees 62 4.4 Net cost of credit 68 3 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT 4.5 Rewards earned 69 4.6 Persistent debt 71 5. Availability of credit 74 5.1 New accounts 74 5.2 Existing accounts 87 6. Practices of credit card issuers 98 6.1 Rewards 98 6.2 Installment plans 106 6.3 Balance transfers 115 6.4 Cash advances 119 6.5 Over-limit transactions 124 6.6 Dispute resolution 125 6.7 Account servicing 129 6.8 Debt collection 141 7. Innovation 159 7.1 Innovations discussed above 159 7.2 Additional developments 165 7.3 Credit card competitors 172 4 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT Executive summaryThis study represents the CFPBs sixth biennial report on the state of the consumer credit card market and continues the approach of the CFPBs previous reports. The CFPB revisits similar baseline indicators to track key market developments and consumer risks as well as the adequacy of consumer protections. Throughout this report, we continue to examine trends by card type and credit score tier, but further segment consumers with the highest scores into two new groups, prime plus (720 to 799) and superprime (800 and above). In a new section, this report examines the market dynamics, concentration, and profitability of the credit card industry in detail, complementing other regulators examination of the safety and soundness of card issuers. We explore new topics that have become more important as the market continues to evolve. For example, the current report explores the prevalence and cost of installment plan features and the dollar value of credit card rewards. Additionally, we discuss issuer practices related to dispute resolution, minimum payments, and servicemember rate reductions. Use of credit: Credit card debt at the end of 2022 surpassed $1 trillion for the first time in our data, but total outstandings remain below pre-pandemic levels when adjusted for inflation. Spending grew to new highs of $846 billion in the fourth quarter of 2022. At the same time, total payments rose, and cardholders paid significantly more of their monthly balances with a greater share of accounts entirely paid off each month. Delinquency and charge-off rates in 2022 were at lower levels than 2019 but increasing, presumably rising with the expiration of COVID-19 related financial relief. Overall market size and structure: Nearly 4,000 issuers, together with dozens of co-brand merchant partners and four major networks, provide cards to over 190 million consumers. The top ten credit card issuers still represent over four-fifths of consumer credit card loans, but the next 20 biggest issuers market share has grown since 2016. Competition and profitability: For companies involved in credit card issuance, servicing, and debt collection, the industry remains profitable. Issuers profitability fell in 2020 but spiked in 2021 and remained at or above 2019-levels in 2022 with an average return on assets of six percent for general purpose cards and two percent on private label portfolios. Point-of-sale; Buy Now, Pay Later (BNPL); and fintech personal loans as well as pay-by-bank options increasingly compete with traditional credit cards for purchase volume and balances. Cost of credit: By some measures, credit cards have never been this expensive, as issuers charged more than $130 billion in interest and fees in 2022 alone. By the end of 2022, interest and fees as an annualized percentage of balances, or the total cost of 5 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT credit, was almost 18 percent on general purpose cards and over 21 percent on private label accounts. Many cardholders with subprime scores are now paying 30 to 40 cents in interest and fees per dollar borrowed each year. Federal Reserve rate increases triggered upward repricing on most general purpose cards, and issuers continue to price well above the prime rate, with an average annual percentage rate (APR) margin of 15.4 percentage points. Fee volume now exceeds pre-pandemic levels. Annual fees grew in 2021 and 2022, while late fees returned to 2019 levels at $14.5 billion as did the cardholder cost of balance transfers and cash advances. Rewards: The dollar value of rewards earned by general purpose cardholders exceeded$40 billion for mass market issuers in 2022. Transacting accounts, or those where the cardholder pays the full statement balance each month, are increasingly benefitting from credit card use. But, when a consumer revolves a balance on their credit card, the cost of interest and fees almost always exceeds the value of rewards the consumer may have earned. Cardholders rewards redemptions have increased, but consumers still forfeit hundreds of millions of dollars in rewards value each year. New features and products: Installment plan features which permit cardholders to convert a credit card purchase to a lower-cost, fixed-rate loan comprise a small but growing segment of the market designed to compete with BNPL. These issuer plans often offer lower finance charges than on revolving debt, but consumers may struggle to make higher monthly payments. Credit card-as-a-service platforms from fintechs to traditional banks have streamlined co-brand partnerships to improve user experience and offer novel rewards with smaller retailers. Some issuers are now approving consumers with only soft inquires on consumers credit reports; others are underwriting consumers without credit scores using new datasets and modeling techniques outside the traditional credit reporting system. Issuers are providing cardholders with more flexible repayment terms and new payment options, including through a growing number of digital wallets. Persistent debt: With the average minimum payment due increasing to over $100 on revolving general purpose accounts in 2022, more users are incurring late fees and facing higher costs on growing debt. We find one in ten general purpose accounts are charged more in interest and fees than they pay toward the principal each year, indicating a pattern of persistent indebtedness that could become increasingly difficult for some consumers to escape. Public relief programs in 2020 and 2021 enabled some consumers to pay down credit card balances, but the number of cardholders facing persistent debt has begun to climb.6 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT Availability of credit: Most measures of credit card availability grew in 2021 and 2022 after a sharp decrease in access during 2020. Application volume for general purpose credit cards reached a new peak in 2022, as issuers increased acquisition efforts and consumer demand grew. For retail cards, in contrast, application volume fell from 2020 to 2022. Approval rates more than rebounded for all card types. The recent upticks in marketing, applications, and approvals led to significant growth in credit card originations in 2021 with even more activity in 2022. Consumers with below-prime scores opened more than 80 million new credit card accounts in 2021 and 2022 combined compared to 63 million over the two year period from 2019 through 2020. Total credit line across all consumer credit cards increased to over $5 trillion in 2022 but remained below 2017 levels in real terms. After declining in 2020, issuers initiated credit line increases more frequently in 2021 and 2022 than they did prior to the pandemic but decreased lines or closed accounts at rates similar to those seen over the past decade. Disputes: Credit card disputes spiked with pandemic-related cancellations and supply chain issues in mid-2020, declined in 2021, but then rose in 2022 as spending grew. Disputed transaction volume for mass market issuers was up 50 percent from 2019 levels to almost $10 billion in 2022, and chargebacks increased more than 80 percent from$3.2 billion to $5.9 billion. Account servicing: Cardholders increasingly use and service their cards through digital portals, including those accessed via mobile devices. Three in four general purpose accountholders are now enrolled in issuers mobile apps, and adoption is increasing, notably for those under 65. The use of automatic payments has likewise continued to climb. New artificial intelligence (AI)/machine learning (ML) technologies are changing how providers service accounts, but concerns regarding the use and sharing of consumer data remain significant, particularly among older cardholders. Debt collection: Compared to prior surveys, the use of email in collections continued to increase in 2022, with consumers opening about one-third of messages. Issuers seemed to leverage the text messaging (or SMS) channel significantly more in 2022 than in prior years with a relatively low opt-out rate at 1.3 percent. New enrollments in loss mitigation programs and total inventory in those programs declined. Post-charge-off settlements fell significantly from their previous peaks during the pandemic. All issuers who sold debt reported deleting the charged-off tradelines from credit reports upon sale, potentially resulting in an incomplete view of consumers debt burden, likelihood of default, and history in the credit reporting system. Throughout this report, we highlight potential areas of concern in the consumer credit card market. Given rising balances and credit costs, more cardholders may struggle to pay their 7 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT credit card bill on time, especially with amounts past-due, overlimit, or under an installment plan added to the minimum payment due. As such, the CFPB will continue to monitor assessments of late fees, reliance upon penalty repricing, and debt collection practices, alongside the disclosure of minimum payments in accordance with CARD Act requirements. Issuers margins are increasing as they price APRs further above the prime rate, potentially signaling a lack of price competition. Instead, companies offer more generous rewards and sign-up bonuses to win new accounts, largely benefitting those with higher scores who pay their balances in full each month. The CFPB will explore ways to promote comparison shopping on purchase APRsa major cost of credit cards that is often unknown to consumers prior to card issuance. We will also monitor changes in rewards value if issuers look to cut costs in response to lower revenue. We encourage new entrantsboth bank and non-bankto work on providing consumers with more transparency, better experiences, and greater access to credit, so long as they comply with existing consumer finance laws.8 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT 1. IntroductionIn 2009, Congress passed the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act or Act). 1 The Act made substantial changes to the credit card market. The CARD Act mandated new disclosures and underwriting standards, curbed certain fees, and restricted interest rate increases on existing balances. Among the CARD Acts many provisions was a requirement that the Board of Governors of the Federal Reserve System (Federal Reserve Board) report every two years on the state of the consumer credit card market. With the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) in 2010, that requirement transferred to the Consumer Financial Protection Bureau (CFPB) alongside broader responsibility for administering most of the CARD Acts provisions. 2 This is the sixth report published pursuant to that obligation, building on prior reports published by the CFPB in 2013, 2015, 2017, 2019, and 2021. 31.1 Report mandateAs mandated by the CARD Act, this report represents the CFPBs sixth biennial review, within the limits of its existing resources available for reporting purposes, of the consumer credit card 1 The Act superseded a number of earlier regulations that had been finalized, but had not yet become effective, by the Office of Thrift Supervision (OTS), the National Credit Union Administration (NCUA), and the Board of Governors of the Federal Reserve System. Those earlier rules were announced in December of 2008 and published in the Federal Register the following month. See 74 FR 5244 (Jan. 29, 2009); 74 FR 5498 (Jan. 29, 2009). The rules were withdrawn in light of the CARD Act. See 75 FR 7657, 75 FR 7925 (Feb. 22, 2010). 2 15 U.S.C. 1616(a) (2012).3 See CFPB, Card Act Report (Oct. 1, 2013) (2013 Report), http://files.consumerfinance.gov/f/201309_cfpb_card- act-report.pdf; CFPB, The Consumer Credit Card Market (Dec. 2015) (2015 Report), http://files.consumerfinance.gov/f/201512_cfpb_report-the-consumer-credit-card-market.pdf; CFPB, The Consumer Credit Card Market (Dec. 2017) (2017 Report), https://files.consumerfinance.gov/f/documents/cfpb_consumer-credit-card-market-report_2017.pdf; CFPB, The Consumer Credit Card Market (Aug. 2019) (2019 Report), https://files.consumerfinance.gov/f/documents/cfpb_consumer-credit-card-market-report_2019.pdf; CFPB, The Consumer Credit Card Market (Sep. 2021) (2021 Report), https://files.consumerfinance.gov/f/documents/cfpb_consumer-credit-card-market-report_2021.pdf. The CFPB also held a conference in 2011 on developments in the credit card market. See Press Release, CFPB, CFPB Launches Public Inquiry on the Impact of the Card Act (Dec. 19, 2012), https://www.consumerfinance.gov/about- us/newsroom/consumer-financial-protection-bureau-launches-public-inquiry-on-the-impact-of-the-card-act. 9 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT market. 4 As was true in the CFPBs previous reports, it addresses the following topics explicitly enumerated by Congress for inclusion in this review: 1. the terms of credit card agreements and the practices of credit card issuers; 2. the effectiveness of disclosure of terms, fees, and other expenses of credit card plans; 3. the adequacy of protections against unfair or deceptive acts or practices relating to credit card plans; and4. whether or not, and to what extent, the implementation of this Act and the amendments made by this Act have affected:a. the cost and availability of credit, particularly with respect to non-prime borrowers;b. the safety and soundness of credit card issuers; c. the use of risk-based pricing; ord. credit card product innovation. 5The CARD Act also requires the CFPB to solicit comment from consumers, credit card issuers, and other interested parties in connection with its review. 6 As in past years, the CFPB has done so through a Request for Information (RFI) published in the Federal Register, and we discuss specific evidence or arguments provided by commenters throughout the report. 7 4 Reference in this report to any specific commercial product, service, firm, or corporation name is for the information and convenience of the public and does not constitute endorsement or recommendation by the CFPB. The CFPB notes that many players in the credit card industry are also entities with which the CFPB has one or more institutional relationships, such as a research partnership or membership on a CFPB-convened body. 5 15 U.S.C. 1616(a) (2012). While this report presents information which may be relevant to assessments of safety and soundness issues relating to credit card issuers, the CFPB does not produce any further analysis on this subject in this report. The prudential regulators (e.g., the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration) have the primary responsibility for monitoring the safety and soundness of financial institutions. 6 15 U.S.C. 1616(b) (2012).7 Request for Information Regarding Consumer Credit Card Market, 88 FR 5313 (Jan. 27, 2023). 10 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT 1.2 Data sourcesThis report leverages several data sources, including: 1. The CFPBs Consumer Credit Panel (CCP): a comprehensive, national 1-in-48 longitudinal sample of de-identified credit records maintained by one of the three nationwide consumer reporting agencies. These data contain no personal identifiers, such as name, address, or Social Security number; 8 2. The Federal Reserve Boards Y-14M (Y-14) Data Collection: monthly portfolio- and account-level data from bank holding companies that have total consolidated assets of$100 billion or more. 9 The de-identified account-level data received by the CFPB cover the period from the middle of 2012 through the present and accounted for just under 70 percent of outstanding balances on consumer credit cards as of year-end 2022;10 3. Data provided in response to two distinct sets of filing orders: a. Mass Market Issuer (MMI) Data: summary data requested from a group of major credit card companies covering topics included in neither the CCP nor Y-14, such as applications, approvals, rewards, disputes, account servicing, debt collection, and other issuer practices;b. Specialized Issuer Data: summary data requested from a diverse group of issuers that in places supplement the Y-14 to allow for a broader or more detailed perspective into credit card usage and cost for specific facets of the market. 8 Other CFPB products, such as Consumer Credit Trends reports, rely on these data. 9 See Bd. of Governors. of the Fed. Rsrv. Sys., Reporting Forms FR Y-14M, https://www.federalreserve.gov/apps/reportingforms/Report/Index/FR_Y-14M (last accessed Jan. 11, 2023) for more information on the Y-14M collection. Information in the Y-14 data do not include any personal identifiers. Additionally, accounts associated with the same consumer are not linked across issuers. The Y-14 does not include transaction-level data. In addition, this study reports only aggregate measures and reveals no information about any specific issuer. These data replace loan-level credit card data collections the CFPB previously collected. The CFPB no longer requires or oversees the collection of any loan-level credit card data on an ongoing basis. 10 The Federal Reserve Board has expanded the fields it collects from bank holding companies over time and has changed the asset threshold for submission from $50 billion to $100 billion since the collection began; therefore, some results reported below do not extend all the way back to 2012. Additionally, these data are periodically revised retroactively, and are therefore not fully static. These issuers represent a large portion of the market but are not necessarily representative of the portion of the market not covered by the data the CFPB receives. The remainder of the market, representing a substantial number of consumer credit cards, are outside the scope of the Y-14 data used by the CFPB because, among other reasons, they are issued by banks owned by bank holding companies with assets of less than $100 billion, or are issued by non-banks, such as credit unions. Results reported from Y-14 data throughout this report should be interpreted accordingly. 11 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT Where these data supplement Y-14 data, those data are collectively called Y- 14+; 114. The CFPBs Quarterly Credit Card Agreement Database: a quarterly collection of most credit card agreements available to consumers as submitted by issuers with 10,000 or more accounts as of the last business day of the calendar quarter;12 5. RFI Comments: 2,936 comments in response to a Federal Register notice addressing all aspects of the review described in Section 1.1 above. 2,728 were submitted as part of a consumer campaign that wrote, I support the Consumer Financial Protection Bureaus work reviewing the work of Credit Card companies and reining in abusive practices. Ive had my own bad experiences, and Im grateful that the CFPB is fighting for me. 208 were not submitted as part of that campaign. Of the substantive, credit-card related comments that were either not part of the campaign or went beyond the campaigns language, 369 were submitted by individual consumers, nine by consumer advocacy organizations, eight by trade groups, five by credit unions, one by a government organization, one by an academic, one by a debt collection agency, one by a fintech, and two in an other category;6. The CFPBs Consumer Complaint Database: a compilation of complaints on credit cards that consumers have submitted to the CFPBs Office of Consumer Response;13 and 7. Third-Party Sources: commercially available or public sources that focus on the credit card industry, including mail volume monitoring reports, industry analyst reports, Securities and Exchange Commission (SEC) filings, studies and data produced by other regulators, academic scholarship, and the press. When adjusting data to account for 11 The Y-14 data cover a large but not representative portion of the credit card market. The Y-14+ data cover a larger and more representative portion of the credit card market, but the remaining uncovered portion is still substantial, and the Y-14+ data should similarly not be considered representative of that uncovered portion. 12 12 CFR 1026.58(c)(5). The database contains most credit card agreements as of quarters end from the third quarter of 2011 to the fourth quarter of 2014, and from the first quarter of 2016 to present. After the fourth quarter of 2014, the CFPB temporarily suspended collection of agreements for one year while the CFPB developed a more streamlined and automated electronic submission system. Submission and publication resumed in the first quarter of 2016. 80 FR 21153 (Apr. 17, 2015); 12 CFR 1026.58(g). Agreements in the second quarter of 2019 are incomplete due to technical submission issues at the CFPB, and agreements in 2020 and 2021 may include omissions due to the CFPBs previous COVID-19 regulatory flexibility statement, see CFPB, Statement on Supervisory and Enforcement Practices Regarding Bureau Information Collections for Credit Card and Prepaid Account Issuers (Mar. 26, 2020), https://files.consumerfinance.gov/f/documents/cfpb_data-collection-statement_covid-19_2020-03.pdf. 13 CFPB, Consumer Complaint Database, https://www.consumerfinance.gov/data-research/consumer-complaints/(last accessed June 27. 2023).12 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT inflation, we use the Consumer Price Index (CPI) for all urban consumers from the Bureau of Labor Statistics. 14The limitations inherent to the CFPBs methodology in this report are substantially similar to those inherent in the CFPBs previous reports on the credit card market. 15 All results reported from data throughout this report aggregate results from multiple industry participants. Each source has particular limitations, as not all data rely upon consistent definitions or cover the same periods, products, or phenomena. Additionally, the available data generally do not allow for definitive identification of causal relationships. Accordingly, correlations presented throughout this report do not necessarily indicate causation. 1.3 DefinitionsThis subsection defines certain additional terms used frequently throughout this report. This is not exhaustive of all remaining defined terms in this report; for example, other defined terms more particular to certain sections or subsections of this report are introduced in those sections or subsections.Throughout this report, the CFPB refers to consumer credit scores. Lenders typically determine consumers credit eligibility and pricing using credits scores based on data from major national consumer reporting agencies alongside other data sources. When reporting results by credit scores in this report, scores are generally grouped into six tiers: superprime (800 or greater), prime plus (720 to 799), prime (660 to 719), near-prime (620 to 659), subprime (580 to 619), and deep subprime (579 or less). 16 Previous reports only used five tiers as they did not break out the prime plus category. Using six tiers better captures differences in cost, use, and availability for the almost two-thirds of cardholders with scores greater than 720. Where historical data are used or in places with limited coverage of cardholders with scores below 620, fewer than six credit score tiers may be represented.Data relied upon in this report include widely used, commercially available credit scores, but as issuers use different credit scores, 17 a given accounts credit score tier may differ from bank to 14 U.S. Bureau of Labor Statistics, Consumer Price Index for All Urban Consumers, https://www.bls.gov/cpi/ (last accessed June 27, 2023).15 See, e.g., 2015 Report, at 27.16 See Section 2.1 for the distribution of cardholders by credit score tier. 17 It is also typical for lenders to supplement commercially-available scores with proprietary models to assess an accounts creditworthiness.13 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT bank. Different credit score models, while fundamentally similar, may include or exclude different information or weight data differently when predicting a consumers relative likelihood of default. Credit scores in the CCP and Y-14 are updated regularly. Unless noted otherwise, accounts and consumers are classified into tiers based on their credit scores at that point in time; therefore, the number of observations in a tier change over time. The CFPB believes that different credit scoring methodologies, over the time periods and set of market participants examined in this report, are sufficiently consistent to remain informative and useful to report aggregate results and changes over time by credit scores. 18 Outstandings, or the nominal amount owed by consumers on a specific date, is one method for measuring consumer credit card indebtedness. A second method entails measuring balances, or the amount owed by consumers at the end of their billing cycle, within a given month. This report uses the term debt to refer to both of these amounts interchangeably. The flexibility in use and repayment of credit cards leads to two types of credit card debt. Consumer credit card debt includes both revolving debtthe amount owed on accounts for which a positive cycle beginning balance was not paid in full by the statement due dateandtransacting debtthe amount owed on accounts for which the non-zero, non-negative balance was paid in full by the statement due date. Most credit cards provide a grace period where, if a cardholder does not carry a balance, they will not accrue interest prior to the due date. Therefore, revolving debt typically bears interest starting from the date of purchase while transacting debt under a grace period does not. Cardholders at any given point can be classified as a revolver or a transactor based on whether they pay their statement in full each month. Throughout this report, we refer to different, and at times overlapping, types of credit cards when describing the market: General purpose cards are those that transact over a network accepted by a wide variety of merchants; Private label cards can only be used at one merchant or a small group of related merchants and lack network branding;1918 See 2021 Report, supra note 3, at 20.19 Private label cards generally transact over a private network maintained by the issuer to which the merchant is granted access. Some cards can transact over both a private label network and a general purpose network. For example, a consumer may be issued a card that features a merchants brand as well as a general purpose network brand. When used at the merchant, the transaction may be routed over the issuers private network, but at other merchants the transaction is routed over the general purpose network. For the purposes of this report, those cards are considered to be general purpose credit cards except where explicitly noted otherwise. 14 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT Co-brand cards are a subset of general purpose cards that include both the badge of a network and branding of a specific merchant such as a retailer, airline, or hotel chain; and Retail cards are a combined category of both private label cards and some general purpose, co-brand cards managed by a business unit that specializes in credit cards offered in partnership with specific merchants. Retail cards do not include network- branded cards that carry hotel or airline branding, even if those cards are managed by a business unit that specializes in retail credit cards. In some sections, data related to co- brand cards managed by a retail unit are not included in general purpose totals, as noted. 15 CONSUMER FINANCIAL PROTECTION BUREAU CONSUMER CREDIT CARD MARKET REPORT 2. Market dynamicsThis new section of the report describes players in the consumer credit card market. This report generally focuses on the state of the consumer credit card market through the lens of cardholders; therefore, this section first establishes the number of consumers with at least one credit card. Then, it addresses issuers as the provider of credit and |
