Technical Q&As – Terms of Credit Card Plans (TCCP) data

The TCCP Survey is conducted by the CFPB to fulfill its obligations under the Fair Credit and Charge Disclosure Act (Act), which amended the Truth In Lending Act (TILA), 15 USC § 1646(b)(1), (2) & (4). TILA requires the CFPB to collect certain credit card price and availability information from a sample of credit card issuers, report this information to Congress, and make it available to the public.

The TCCP Survey is conducted twice per year, usually March and September unless otherwise stated in the Order requiring the financial institution to complete the TCCP Survey. (For more information about credit card issuers’ compliance, see the CFPB Compliance Aid FAQs).

For information about the data collected in the TCCP Survey, a description of all data fields can be found in the TCCP Data Dictionary, available at https://www.consumerfinance.gov/data-research/credit-card-data/terms-credit-card-plans-survey/data-dictionary/.

TILA requires the TCCP Survey to include at least 150 issuers, made up of the 25 largest issuers of credit cards and not less than 125 additional financial institutions selected by the CFPB. The CFPB may require any financial institution that offers credit cards in the U.S.to participate in the survey. This includes domestically-chartered commercial banks, U.S. branches and agencies of foreign banks, credit unions, and credit card issuers.

The CFPB ranks credit card issuers by credit card loan balances as of the most recent calendar year-end. Loan balances are considered for all consumer credit card accounts issued by that financial institution, including loans that have been sold to or managed by third parties, or otherwise held off-balance sheet. The primary sources for credit card loan balances are Federal Financial Institutions Examination Council (FFIEC) Call Reports, National Credit Union Administration (NCUA) Call Reports, and commercially-available sources such as The Nilson Report^[1]. Affiliated legal entities are treated as one issuer for the purpose of identifying the largest 25 credit card issuers. The CFPB reviews the top 25 credit card issuers each survey cycle and updates the list, making corresponding changes to the survey recipient list, to reflect mergers and acquisitions among the largest 25 credit card issuers. The combined consumer credit card loan balances of the 25 largest credit issuers historically accounts for about 95 percent of the credit card market.

[1] The Nilson Report is used to supplement Call Report information for large issuers that hold a majority of managed credit card loans off-balance sheet. For example, see The Nilson Report, No. 1280 (Feb. 2025), Top 50 Visa and Mastercard Credit Card Issuers in the US Ranked by Outstandings in 2024.

Approximately 150 financial institutions are selected from the list of credit card issuers, excluding the largest 25. The sample is derived from the roughly 2,200 banks and credit unions with credit card balances exceeding $1 million. To ensure an equitable geographic distribution within the sample, the CFPB selects at least two issuers per state, using the state where the institution is chartered. We do not sample institutions chartered or headquartered in U.S. territories. The combined consumer credit card loan balances of the additional 150 financial institutions typically represent less than 1 percent of the credit card market.

Beginning with the January 1 – June 30, 2025 reporting period, the CFPB uses a stratified random sampling method where approximately 150 issuers are allocated proportionally to state population with a minimum of two issuers per state. In prior reporting periods, the additional 150 institutions were selected based on state, institution type, and size, but were not selected using random sampling.

TCCP Survey data are generally made available to the public between three months and nine months following the end of the reporting period. Data are collected for a six-month reporting period and the survey collection process takes about three months, allowing time for issuers to complete the survey and for the CFPB to consolidate and publish the results.

The final sample size for the January 1 – June 30, 2025 TCCP Survey is smaller than in previous survey cycles. This decrease in responders is likely due to a new sampling approach developed in this cycle to be more consistent with the tenets of the Restoring Gold Standard Science Executive Order (EO 14303). First, the CFPB expanded the sampling frame beyond the approximately 700 credit card issuers already in its Collect system to about 3,600 financial institutions that report credit card assets on its balance sheet. Second, the CFPB employed a stratified random sampling procedure to select firms that would be asked to participate in the survey.

The CFPB sent survey Orders to roughly 175 institutions, similar to prior cycles. Previously, sampling frames were limited to the population of financial institutions with 10,000 or more open accounts that are required to submit credit card agreements to the CFPB through the Collect system. The new approach added credit card issuers with fewer than 10,000 open accounts that had not previously participated in the CFPB’s credit card agreement or survey collections. The lower response rate might have been caused by unfamiliarity with the CFPB’s requests. For example, several institutions asked CFPB staff if the requests were legitimate, spam, or phishing attempts.