A new report from the Center for American Progress argues that to more effectively influence the behavior of credit card companies, an incentive-based system of disclosure—one that relies on the profit-seeking interest of companies to change their behavior—should be added to the current credit card disclosure regime.
A good model for developing an incentive-based credit card disclosure system may already exist. At least, that appears to be the case with respect to the federal government’s New Car Assessment Program. Congress called for the creation of NCAP in response to mounting concern raised in the 1960s and early 1970s about the safety of automobiles. At that time, injury and fatality rates related to automobile accidents were on the rise and the purpose of NCAP was to “encourage manufacturers to make safety improvements to new vehicles and provide the public with information on the relative safety of vehicles.” To this end, NCAP instituted a five-star rating system that created an incentive for companies to produce safer cars. And the results have been dramatic.
The positive results from NCAP show that an incentive-based safety disclosure system can have dramatic effects on the behavior of companies. This gives reason to believe that an incentive-based model would be a powerful tool for influencing the behavior of credit card companies as well. A system for credit cards could be modeled after the NCAP system, perhaps using a less detailed red-yellow-green formulation instead of the five-star crash rating system. Specifically, like NCAP’s system, an incentive-based system for credit cards could:
- Empower the Federal Trade Commission to assess the safety of a credit card by testing for a limited set of credit card features that are deemed the most risky for consumers, among them: unilateral “at any time, for any reason” provisions for changing the rate of interest on credit cards; universal default provisions; the underwriting standards used to issue the card; the card’s interest rate spread between the introductory rate and the maximum rate allowed; and retroactive application of interest rate increases.
- Assign a red rating if the feature in question is below a pre-established basic standard of safety, a yellow rating if the card meets the basic standard of safety, and a green rating if the card exceeds the basic standard of safety.
- Require credit card companies to display the government safety rating on the card itself, as well as on credit card contract. The rating label on the contract should explain the basis for each card’s safety rating and the maximum available rating.
- Develop a public education component for the new rating system that explains the ratings to consumers in a clear and concise way and provides consumers with a list of available government resources online and in print to help address any questions they have about the safety ratings system.
The purpose of the report is to make the case for adding an incentive-based disclosure system to the current disclosure regime. As fundamental economic theory suggests, this addition will make the credit card disclosure system more effective at influencing the behavior of credit card companies than a purely moral-based system. Moreover, an incentive-based system will have the added benefit of fostering a market for “safe” credit cards.