2015 Star Ratings. Credit Cards. Discussion paper

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1 2015 Star Ratings Credit Cards Discussion paper Defaqto Limited All rights reserved. No parts of this publication may be reproduced in any form by any means, whether electronic, mechanical, optical or any other or be stored in a retrieval system without the express written permission of the publisher. The publisher has taken all reasonable measures to ensure the accuracy of the information and Ratings in this document and cannot accept responsibility or liability for errors in or omission from any information given and for any consequences arising.

2 About this document This document outlines the key developments and trends that will inform the criteria we use for the 2015 Star Ratings for Credit Cards covering Standard Credit Cards and Premier Credit Cards and, based on these, sets out the areas where we would like to consult the industry as part of ensuring that our Ratings process remains robust and transparent. 2

3 Key developments and trends The market We have reviewed developments in the credit card market, considering legislation and regulation, provider changes, and product changes and have concluded that the following significant changes will be considered in our Ratings for 2015: There has been a large amount of change in the provider market over the past couple of years, with a number of distributors exiting the market during early The number of different credit cards in the market reduced markedly compared with 2013 No of credit cards by type No of card providers by type Standard Premier Standard Premier Legislation and regulation The biggest developments in this area at present is the FCA takeover of responsibility for regulating consumer credit, which includes Credit Cards, from April 2014, and the impending European Commission restriction on the level of Merchant Interchange Fees, which might come into force towards the very end of FCA takeover of regulating consumer credit We experienced a marked reduction in the number of distributors of standard credit cards when the FCA began regulating the credit card market The FCA investigation into the sale of add-on insurance may well change the focus of the relative importance of various card benefits, as the regulator may choose to include card benefits in its investigation into product add-ons As yet it is too early to know what action, if any, the FCA might take in the credit card market that would lead to a change in card features and benefits, so we intend to keep this area under review over the summer months but have no plans to change Rating criteria for FCA reasons at present Restriction on the levels of Merchant Interchange Fees by the EC In 2013 the European Commission announced plans to cap the level of Merchant Interchange Fees for credit and debit card transactions. The maximum levels of fees which will be allowed are considerably lower than at present and may well change the business dynamics of the credit card market, particularly for those card providers with customer reward schemes The restrictions are expected to come into force towards the end of

4 It is too early to establish or guess at the likely changes to credit cards; as a result we currently have no plans to change to the criteria included in credit card Ratings 4

5 Providers We reviewed how the make-up of distribution has changed over recent years, comparing 2014 to 2013 and The relative proportion of standard and premier cards has remained relatively unchanged over the past two years, although the number of different cards in the market has reduced markedly in the past 12 months Many of the distributors that left the market were providers charity brands that were withdrawn when the FCA took over regulation of consumer credit in April 2014 Despite the changes in the numbers of distributors we cannot detect any marked change in the overall types and quality of cards being offered, so feel no need to change our Star Rating criteria for this Products/propositions We looked at the way in which providers' products and propositions are changing over time. Many of the changes in the credit card market over the past year have been in the area of introductory offers to attract new customers; the Star Ratings currently exclude introductory offers. It is important when comparing cards to look at the terms that apply once any introductory deal has expired, we therefore intend to add the ongoing Balance Transfer AER and Cash Advance AER to the Rating criteria for both card types Some providers have introduced the ability for customers to obtain an indication as to whether they will be eligible for a card before undergoing a full credit check when applying. This is particularly useful for standard cards (as those applying for premier cards are unlikely to fail any credit check); we intend to add Eligibility Check to the Rating criteria for Standard Credit Cards from 2015 One area of growth in recent years has been the provision of cashback benefits, which we already include in the Ratings for both Standard and Premier Cards. We have reviewed the features included in the Ratings and proposed that for Standard Cards we will replace the Cashback on a 100 monthly spend with the cashback on 500 monthly spend, to reflect the higher benefit available for using cards more frequently The advent of widespread use of smartphone technology means that many customers can now receive on their phone; to reflect this we intend to add the availability of account updates to both card Ratings (we already include text updates in the Ratings) Some of the Premier Card points schemes allow customers to exchange reward points for Airmiles or their equivalents, and we intend to add this to the Premier Card Ratings We currently have two criteria in the Ratings for Cash Advance charges on the card (based on the % fee and the fee if there is one); this effectively double counting and we intend to remove the Cash Advance Charge criteria from both Standard and Premier Card Ratings A reducing number of Premier Cards give customers a monthly reward as a fixed amount of money; we intend to remove this criterion from the Ratings 5

6 Key implications for the 2015 Ratings process Product definitions For 2015 the definitions of how Defaqto classify credit cards will be as follows: Credit Card Type Criteria for Inclusion Ratings Available Premier Marketed to High Net Worth customers, AND: Premier Credit Card Minimum income 30,000 or higher, OR Annual fee 60 or higher, OR Concierge service Standard Mainstream cards Standard Credit Cards Product area weightings Making the changes we described above will slightly alter the share of product features in the various Ratings areas. The criteria mix for the 2015 Star Ratings would be as shown below 2015 Star Rating Criteria Category No of Criteria Standard Share No of Criteria Premier Share Cost 12 39% 12 27% Service 8 26% 11 25% Incentive 4 13% 7 16% Security 2 6% 4 9% Access 5 16% 5 11% Travel 0 0% 5 11% TOTAL These criteria reflect that in Standard Credit Cards the balance is mostly towards cost and services, while in Premier Cards we have more emphasis on travel benefits and incentives, and slightly less emphasis on costs and access issues. 6

7 What does good look like? For 2015 we see no need to change the core criteria for 4 or 5 Star products from those which are currently being applied. Criteria category Star Rating Area Core Criteria Standard Cards Premier Cards Access Transfer of Existing Debt Instant Online Decision Transfer of Existing Debt Instant Online Decision On-Line Access Cost Dormancy Fee Dormancy Fee Security Internet Fraud Protection Internet Fraud Protection 7

8 Areas for discussion These are the areas where Defaqto would like to discuss their proposals, and receive any feedback that you might have. Increasing the number of criteria relating to the costs of running the card after any introductory deals have expired To reflect more on the ongoing features of credit cards Adding the preapplication Eligibility Check to the Ratings only for Standard cards Customers might be scared about being fully credit checked for a card and then refused This benefit is more useful to those applying for standard cards rather than premier cards No changes to the Rating criteria as a result of the FCA investigation into the sale of addons Unclear that the FCA will try to prevent the inclusion of benefits like travel insurance, home emergency cover etc. from credit cards, given the recognised utility of some of these add-ons For the present we see no reason not to include these account benefits in our Ratings for Premier cards Change to the monthly spend bands for cashback benefits on standard cards Move from comparing cashback on 100 and 250 per month spend to 250 and 500 No change to the Premier card cashback criteria of 500 and 1,000 per month Move towards more mobile banking on smartphones Inclusion of the provision of account updates in Ratings for both card types Continue comparing provision of text message updates No changes to Rating criteria as a result of the EC restriction on the level of Interchange Fees Proposals unlikely to come fully into force until later in 2015 Too early to predict what card feature changes are likely to arise Any other changes to product features not considered. 8

9 Appendix: Proposed 2015 criteria Based on the above analysis, we propose including the following criteria in our assessment process for the 2015 Ratings (core criteria are in bold text; new criteria are highlighted in green). Proposed criteria Standard Credit Cards Min Income ( pa) Dormancy Fee Eligibility Check Contactless Payment Limit Transfer of Existing Debt Outgoing Direct Debit Balance Transfer Fee (%) Free Warranty Cover Balance Transfer AER Max Purchase Protection Money Transfer Facility Internet Fraud Protection Cash Advance Charge % Air Miles Cash Advance AER Shopping Reward Programme International Charges % Points Scheme Representative APR Cash-Back 250 Monthly Annual Fee ( ) Cash-Back 500 Monthly Interest Charged from Free Text Alerts Interest Free Period Free Updates Interest Free Period Cash Instant Online Decision Late Payment Charge On-Line Access Over Limit Charge The table below sets out the 2014 criteria that we are planning to remove for Criteria planned for removal Standard Credit Cards Cash Advance Charge Cash-Back 100 Monthly 9

10 Proposed criteria Premier Credit Cards Min Income ( pa) Free Price Protection Eligibility Check Internet Fraud Protection Transfer of Existing Debt Travel Medical Insurance Balance Transfer Fee (%) Travel Cancel Insurance Balance Transfer AER Max Lost Luggage Cover Money Transfer Facility Max Travel Delay Cash Advance Charge % Air Miles Cash Advance AER Shopping Reward Programme International Charges % Points Scheme Representative APR Points Swap for Airmiles Annual Fee ( ) Cash-Back 500 Monthly Interest Charged from Cash-Back 1000 Monthly Interest Free Period Emergency Card Interest Free Period Cash Emergency Funds Late Payment Charge Free Text Alerts Over Limit Charge Free Updates Dormancy Fee Home Emergency Cover Contactless Payment Limit Roadside Assistance Outgoing Direct Debit Concierge Service Free Warranty Cover Airport Lounge Access Refund Protection Instant Online Decision Max Purchase Protection On-Line Access The table below sets out the 2014 criteria that we are planning to remove for Criteria planned for removal Premier Credit Cards Cash Advance Charge Fixed Monthly Reward 10

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