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Bank Fees, the CFPB, and a New Era of Deregulation

What’s changed in 2025, and what it means for credit card issuers and payment platforms.

In January, we published an article outlining how the credit card and payments landscape might shift depending on the outcome of the 2024 election.

When we wrote that post, the industry was in the thick of a regulatory crackdown on Buy-Now-Pay-Later (BNPL) rewards programs, and followed bipartisan campaign promises to cap interest rates. As we saw it, either administration could surprise the industry—with Trump touting an unlikely 10% interest cap and Biden’s regulators tightening the screws on digital credit.

Now, with a clearer picture of the Trump administration’s second term, it’s fair to say that deregulation will dominate the consumer finance landscape, from credit card rates to crypto to BNPL. 

The Quiet Dismantling of the CFPB

The Consumer Financial Protection Bureau (CFPB), long a punching bag for Republicans, has been the centerpiece of the administration’s rollback strategy. While it hasn’t been abolished outright, its core enforcement powers have been scaled back in a major way.

The agency’s headcount has reportedly been slashed by nearly 90%, and insiders say that enforcement actions have all but stopped. Beyond reducing bureaucracy and cost, this move is likely meant to weaken an agency that had recently looked very closely at new financial instruments like cryptocurrency, reward programs and BNPL.

In practical terms, this leaves consumers with fewer avenues for complaints and makes regulatory risk less of a concern for card issuers and payment firms. Rewards programs, which had been under scrutiny for practices like point inflation and complicated redemption policies, might be free to evolve without the level of oversight.

BNPL: A Regulatory Pause

The reclassification of BNPL as “credit cards” under certain interpretations, known as Regulation Z, had seemed poised to change the game. With the Supreme Court upholding the Biden-era interpretation last year, platforms like Affirm and PayPal were bracing for tighter income verification, fair lending scrutiny, and even caps on “loan stacking.” But in May of 2025, the CFPB announced that it would no longer apply that interpretation.

For the BNPL sector, the message is clear—expand while the window is open. Investors have taken note, pushing valuations back up across the space as regulatory fears recede.

Bank Fee Rules Reversed

One of the most visible shifts in the early months of Trump’s second term has been the rapid rollback of Biden-era restrictions on “junk fees.” These included caps on late payment penalties and overdraft fees, and would have significantly affected the revenue mix for banks and card issuers. Critics argued that these rules protected consumers from predatory behavior. Supporters of the rollback claimed they were government overreach into a private pricing model.

Either way, the rules are now gone. Banks and issuers are no longer constrained by the CFPB’s proposed $8 cap on late fees, and many have quietly restored pre-2024 fee structures. The rollback is a win for traditional institutions and may allow fintechs to revise their own fee-light strategies.

Interest Rate Cap? Don’t Count on It

On the campaign trail, Trump floated a surprising populist proposal: capping credit card APRs at 10%. The idea even got praise from Senator Bernie Sanders. But since the inauguration, it’s been radio silence. That’s not surprising. Such a cap would not only require legislation, but would also upend the credit industry in unpredictable ways.

More importantly, the Trump administration’s broader deregulatory push makes a strict interest rate cap feel out of sync.

Crypto and Alternative Payments Get a Boost

As traditional regulation is being rolled back, some sectors are feeling a tailwind. Crypto payments—largely frozen in place under Biden’s cautious posture—have seen a revival. Bitcoin’s surge past $100,000 was largely a reaction to a friendlier White House tone.

The Trump Administration has signaled that it would push back against SEC scrutiny of decentralized finance platforms. It is also pushing for a Crypto Reserve to help strengthen the dollar.

This may signal the emergence of a dual-track system: tight controls for legacy financial institutions that remain under state supervision, and freer rein for emerging technologies and payment rails that operate outside traditional frameworks.

Adaptability Is Still the Name of the Game

If 2024 was the year of regulation, 2025 is shaping up to be the year of rollback and realignment. But uncertainty hasn’t gone away. Instead of regulatory constraints, the industry might feel some political whiplash, with rules swinging depending on who holds power.

For payment platforms, banks, and fintech providers, the lesson is not to bet on permanence. Reward structures, fee models, and credit innovations may be free to evolve again, but those freedoms are only as stable as the next election.

COCARD: Focused on What Doesn’t Change

At COCARD, we’ve weathered more than a few cycles, from technology to regulation. Our core approach hasn’t changed: remain agile, adopt compliant technology early, and keep our merchant network informed. Whether the pendulum swings toward regulation or deregulation, we’re committed to building a payment ecosystem that adapts without missing a beat.

If you’d like a partner who knows how to thrive and innovate through uncertainty and opportunity, reach out today


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