Banking and Finance Law Daily Wrap Up, CREDIT, DEBIT AND GIFT CARDS—ABA asks CFPB to withdraw guidance on credit-card rewards programs, (Dec 4, 2025)

By Nora Macaluso

The Biden-era guidance accompanied a report on consumer complaints about rewards programs.

The American Bankers Association has asked the Consumer Financial Protection Bureau to withdraw Biden administration guidance stipulating that credit-card issuers could be breaking the law if they devalue earned rewards or prevent customers from redeeming promised rewards.

The banking group also asked the CFPB to take down the published circular, an “Issue Spotlight” on the Bureau’s website highlighting a report detailing consumer complaints about rewards programs, and a press release announcing the report, as well as a statement supporting a Department of Transportation inquiry into airline rewards programs.

The documents “sought to turn popular and widely available credit card rewards programs into a target for CFPB examiners,” the ABA said in a Dec. 3. 2025, letter to CFPB Acting Director Russell Vought.

“These publications raised unfounded concerns about the market for credit cards that offer rewards, including by stating that consumer complaints indicate ‘concerning patterns’ in market practices,” and “appear designed to pressure rewards card issuers” by promising CFPB action, the ABA said in its letter.

The 2024 report cited confusing redemption requirements, changing terms, customer service issues, and points cancellation as frustrations for cardholders. The Bureau reminded card issuers that consumer protection laws apply to such programs (see Banking and Finance Law Daily, May 9, 2024)).

“Credit card companies promise upfront benefits for signing up and using their rewards card but often bury complex terms in the fine print for using the rewards,” Rohit Chopra, director of the CFPB at the time, said in a statement. “The CFPB will be looking for ways to protect people's points, stop bait-and-switch scams, and promote a fair and competitive market for credit card rewards” (see Banking and Finance Law Daily, Dec. 18, 2024).

But “contrary to the CFPB’s assertions, credit card rewards programs are widely accessible, valuable, and clearly understood by consumers across all income levels,” and complaints about rewards comprise just 0.09% of all complaints submitted, the ABA said.

The ABA also said the guidance did not go through a public comment process. “This misuse of guidance creates unnecessary confusion for regulated entities, deprives the industry of fair notice and undermines the legitimacy of the regulatory process,” the association said.

“The CFPB’s attack on credit card rewards programs threatens their sustainability and flexibility to meet consumer demands,” the ABA letter said. “Fierce” competition has led issuers to offer features such as cash back, travel benefits, and points that can be redeemed for merchandise, the association said. “Consumers at all levels” benefit from the programs, the ABA said.

“While industry generally welcomes guidance that helps it understand and comply with the law, the CFPB has, in the past, too often characterized documents as guidance when, in fact, they were rules that were legally required to undergo a notice-and-comment process,” the letter said. “In the most egregious cases, CFPB guidance has announced expectations that exceed the CFPB’s statutory authority, as is arguably the case in the Rewards Circular. This misuse of guidance creates unnecessary confusion for regulated entities, deprives the industry of fair notice, and undermines the legitimacy of the regulatory process.”

Companies: American Bankers Association

RegulatoryActivity: CFPB ConsumerCredit CreditDebitGiftCards DirectorsOfficersEmployers DoddFrankAct GCNNews UDAAP