10% rate cap would hit card issuers hardest, analysis finds

A proposed federal 10 percent APR cap on credit card interest rates is drawing fresh scrutiny as a new analysis argues the impact would be highly concentrated among a small group of specialist card issuers, rather than broadly destabilizing the U.S. banking system.

The analysis, published Feb. 13, 2026, by community-bank technology firm Amberoon under its Statum analytics brand, reviewed 4,284 FDIC-insured banks using Q4 2025 FFIEC Call Report data. Amberoon concluded that only 13 institutions would face a “critical” outcome in which a cap would push them into negative profitability because their business models rely heavily on high-yield revolving credit. The report identifies those banks as specialized card-centric entities, including Synchrony, Comenity, Capital One, Barclays Delaware and American Express Centurion, among others.

Amberoon’s central claim is that the policy functions more like a precision strike than an industrywide shock. It estimates 85.3 percent of banks in the dataset hold zero credit card exposure, leaving the majority of community and regional institutions largely insulated from direct earnings pressure. Meanwhile, the report estimates $0.62 trillion in credit card loans across the system it analyzed and calculates roughly $68 billion of net interest income at risk under a 10 percent cap scenario.

A debate heavy on rhetoric, light on quantified impacts

The proposal has circulated publicly in recent weeks amid rising political attention to consumer borrowing costs. Large issuers and banking trade groups have warned that a cap could constrict credit, especially for non-prime borrowers, and shift demand toward higher-cost alternatives.

Amberoon’s report positions itself as a response to what its CEO, Shirish Netke, described as doomsday narratives that lack bank-by-bank quantification. The firm argues modern data tools make it possible to identify exactly which institutions would absorb the most pressure, which communities might feel second-order effects and where capacity exists to backfill credit.

How Amberoon modeled the hit

Amberoon’s methodology uses call-report measures of credit card loans and applies an estimated yield reduction based on the gap between an observed average APR of 20.97 percent and the proposed 10 percent cap. It then translates that yield compression into a projected return-on-assets impact and sorts banks into four tiers.

In its results, the “critical” tier is dominated by card specialists with unusually high credit card concentration. Amberoon highlights Comenity as the most exposed in percentage terms and Synchrony as the largest critical institution by assets. It also flags a “stressed” tier of 223 banks that would remain profitable but face meaningful earnings pressure, potentially prompting tightened underwriting, repricing of products or reduced appetite for revolving credit.

Amberoon notes that some banks appear in a negative-ROA bucket for reasons unrelated to the cap—institutions already unprofitable before applying the modeled rate compression.

Second-order effects: where disruption may land

Even if the direct earnings impact is concentrated, Amberoon argues the consumer and small-business effects could be broader if specialist issuers respond by shrinking lines, closing accounts or moving upmarket. In its view, that is where a cap’s ripple effect could be felt, particularly by small businesses that use cards as backup operating liquidity for inventory and payroll.

The report also sketches downstream shifts that industry leaders have warned about: less generous rewards economics, new or higher account fees, and migration of credit demand to BNPL, payday and other alternative channels if mainstream revolving credit becomes uneconomic under a 10 percent ceiling.

A potential opening for community banks

One of Amberoon’s more contrarian takeaways is that a cap could create a strategic opportunity for banks with little card exposure. If large issuers retrench, Amberoon contends that community banks—already oriented around relationship lending—could expand small business lines, personal loans and other installment products to meet displaced demand. The report urges preparation: building digital origination, underwriting capacity and product strategies that could scale if credit availability shifts quickly.

Amberoon’s analysis assumes an immediate, uniform cap with no exemptions and acknowledges that real-world outcomes would depend on implementation details, phase-in timing, legal constraints and bank behavioral responses. But its bottom line is clear: the profitability shock is not evenly distributed, and any serious debate over a rate cap should begin with where the exposure actually sits.

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