Matters relating to credit card interest rates Submission 23

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1 - Matters relating to credit card interest rates

2 Contents 1. INTRODUCTION 2 2. CUSTOMER EXPERIENCE 2 3. UNDERSTANDING THE PRODUCT 4 4. COMPETITION IN THE CREDIT CARD MARKET 5 5. COST OF PROVIDING CREDIT CARD PRODUCTS 6 6. ATM FEES 8 1

3 1. Introduction Commonwealth Bank of Australia (Commonwealth Bank) welcomes the opportunity to provide a submission to the Senate Economics References Committee Inquiry into matters relating to credit card interest rates. Credit cards play an important role in the financial arrangements of individuals, businesses and households. They are used to make payments remotely, to access finance while overseas, to cover costs in an emergency and to provide a convenient and affordable way to meet everyday spending needs. Awards cards also earn points which can be redeemed for products, gift cards, cash back or frequent flyer points. Additionally, credit cards provide retailers with fast and secure payments, in store, over the phone and online. Recent public commentary has focused on an apparent low correlation between credit card interest rates and the official cash rate. Credit cards are a unique financial product, bringing together the credit of a personal loan with the convenience and security of a debit card, as well as providing added benefits such as complimentary travel insurance and interest free periods. Innovations such as Tap & Go, security chips and Commonwealth Bank s proprietary Lock, Block & Limit function have seen this convenience and security grow significantly in recent years. Compared with home loans, credit cards are subject to proportionally higher direct operating costs and higher risk profiles given the unsecured nature of the credit on offer. As credit cards are unsecured lending, they are sensitive to market pressures and the economic environment, particularly the unemployment rate. Credit card issuers need to take into account the economic cycle when setting rates. As will be illustrated, only 22 per cent of the cost of providing a credit card is the cost of funds. We believe our pricing of credit card interest rates appropriately reflects the risk, operational cost, product features and competition in the market. This submission outlines the customer experience, the types of credit card products Commonwealth Bank offers, the importance of financial literacy, the state of competition in the credit card market and the cost of providing credit cards and ATMs. 2. Customer experience Commonwealth Bank provides 2.9 million credit card accounts to its customers in Australia. Credit cards are versatile products with features, benefits and price points designed to meet a range of customer needs. They provide customers with a convenient means of payment and a line of unsecured credit which they can use at any time. Having access to credit at short notice can be particularly beneficial for customers who are travelling or experience unexpected financial costs they are unable to meet. All Commonwealth Bank cards come with up to 55 days interest free on purchases, making credit cards an affordable, quick and easy way for customers to meet costs. 2

4 Credit cards generally offer a range of other benefits to customers including: a low cost, permanently available line of credit with global acceptance for everyday spending, travel needs, cash advances and credit to use in the event of an emergency; state of the art security and fraudulent transaction detection, with a 100% money-back guarantee; dispute and chargeback rights; innovative payment technology, including contactless (Tap & Go) and mobile device payment options; emergency assistance while overseas; loyalty programs; and complimentary travel insurance benefits (for Gold, Platinum and Diamond cards). Commonwealth Bank credit cards also include a range of unique customer benefits such as: offering control to lock or unlock certain transaction types (such as ATM cash advances or international transactions) and set daily spending limits, all from the CommBank app or Netbank; the ability to redeem Award points directly at point-of-sale at Myer or Flight Centre; and the ability to tap and pay using PayTags and contactless technology on Samsung smartphones. Credit cards also benefit retailers and the broader economy, providing fast and secure payments both in store and remotely (either over the phone or online). Commonwealth Bank business customers also benefit from same day everyday settlement into their business transaction account for the day s trades, regardless of whether credit card customers default on their repayments. Card Types Commonwealth Bank offers three simple types of personal credit cards including Low Fee, Low Rate and Awards, making it easy for a customer to choose the most appropriate card for their needs. Low fee cards are commonly used by customers who want the security of having a standing line of credit for use in times of emergency or when facing unexpected costs, but for whom awards points and other premium benefits are not important. Our low rate card is commonly used by customers who use their credit card as a revolving line of credit and are unlikely to pay the full balance within the 55 day interest free period. For these customers the low rate card provides an opportunity to minimise interest costs. It also provides our customers with credit in a cheaper, quicker and more convenient way than an unsecured personal loan. Finally, our Awards cards reward customers with points for every eligible dollar they spend. These points can be redeemed for frequent flyer points, cashback, gift cards or one of the 1,000 items available through the CommBank Awards Program. Provided these customers pay off their balance within the 55 day interest free period, they can obtain a financial benefit just by using their credit card instead of paying with cash or EFTPOS. Premium tier Awards cards also include additional benefits such as complimentary travel insurance. Table 1 illustrates some of the features of our three core credit card types. 3

5 Table 1. Commonwealth Bank credit card types and their features Low fee card Low rate card Awards cards Rates and fees Interest rate 19.74% 13.49% 20.24% Cash advance rate 21.24% 21.24% 21.24% Annual fee From $0* From $59 From $59 Interest free purchases Up to 55 days Up to 55 days Up to 55 days Features and awards Fraud money back guarantee Yes Yes Yes Lock, block and limit Yes Yes Yes Overseas travel insurance Available on Gold Available on Gold Available on Gold, Platinum and Diamond Awards points No No Yes * If customers spend $1,000 per annum (Standard) and $10,000 per annum (Gold) 3. Understanding the product For customers to make the right financial choices to suit their situations, it is important that they understand the products they are selecting. Commonwealth Bank considers that financial literacy is vitally important in ensuring that customers get the most benefit from financial products. To ensure that Commonwealth Bank customers select and understand the best credit card for their circumstances, including their ongoing obligations, we provide a range of customer centric tools and features including: card selector and comparison tools; educational content which explains how interest is calculated and when it is charged; information on each monthly statement which explains payback periods should only the minimum required repayment be made; autopay functionality (available to automatically pay the minimum payment, full balance or other fixed amount); financial health checks through staff in any of our branches; SMS and payment reminders; and budgeting tools within NetBank. Figure 1. Two customer examples of information displayed on statements 4

6 Commonwealth Bank has observed customers using these tools to make decisions about the best credit cards to suit their circumstances and about how they use and repay those cards. The low rate card has become Commonwealth Bank s most popular credit card. Our low rate card now comprises more than 42 per cent of our new applications, compared to around 33 per cent in Existing customers on Commonwealth Bank Awards and Commonwealth Bank low fee cards have transferred more than $1 billion in balances to low rate cards since 1 July This illustrates the transparency of pricing and the ease with which customers can switch to a lower interest rate. As at 31 March 2015, approximately 57 per cent of Commonwealth Bank credit card holders pay no interest at all as they pay their credit card balance in full each month. Of those customers who do pay interest, the most popular card is our low rate card. Data at an industry level indicates similar trends. In recent years customers have increasingly chosen to pay off a larger proportion of their credit card balances. Since 2011, repayment rates have grown more than five times as fast as balances (21 per cent repayment growth, compared to 4 per cent balance growth). The proportion of outstanding balances accruing interest has also fallen over the last four years. Of the $51 billion in outstanding industry balances as at June 2015, $33.1 billion (64 per cent of total) was accruing interest, a 9.3 per cent decrease from June 2011 ($36.5 billion). The reduction in balances accruing interest can be mainly attributed to higher customer repayment rates and aggressive zero per cent balance transfer offers. In an estimated 7 per cent of industry balances were on zero per cent balance transfers for up to 24 months from the time of activating the account. 4. Competition in the credit card market Commonwealth Bank believes that there is strong competition in the credit card market both in pricing and product features. Since 2011, competition within the credit card market has increased. There are now around 58 brands offering approximately 171 credit cards in Australia. In recent years non-finance companies have also increased their participation in the credit card market, with retailers such as Coles and Woolworths now offering multiple credit card products. In a 2015 RFI Group consumer survey, Coles was rated second, ahead of many traditional providers, as the brand to whom customers will most likely apply for a new card 1. Credit card issuers are also increasingly offering attractive incentives for customers to take up their products or switch between providers. These include: balance transfers, where existing credit card holders can transfer their debt from their current provider to another credit provider for low interest rates (currently zero per cent interest rates for periods up to 24 months are on offer); 1 RFI Cards Council 5

7 low introductory interest rates on purchases (with no interest charged for new purchases for periods up to 12 months); annual fee waivers; cashback credits; and lump sum loyalty or frequent flyer points. The number of these types of offers (typically valued at several hundred dollars per customer) and the prevalence of their advertising to the public is in Commonwealth Bank s view an indication of the vigorous competition in the market. Further enhancing the competition is a rapidly growing industry of intermediaries such as Mozo, InfoChoice and Cannex who make it easy for customers to compare credit cards and switch to the best deal. Online credit card comparison sites account for an estimated 10 per cent of new credit card applications. Some issuers provide approval decisions within 60 seconds of application, making it a simple process to switch providers. Commonwealth Bank credit card customers can also switch between our own proprietary card pricing and features, in some instances without changing their credit card number and scheduled direct debits. For example, if a Gold Awards card customer wants to switch to a Gold low rate card, this can easily be achieved without disrupting their direct debit arrangements or requiring a new card number to be issued. 5. Cost of providing credit card products We note recent commentary surrounding the level of credit card interest rates and their relationship with the RBA cash rate. When compared to similar types of unsecured credit, and taking into account the other features and benefits offered by credit cards, our interest rates are competitive and appropriately priced. The costs associated with providing unsecured credit to customers through credit cards differ significantly from other banking products such as home loans or personal loans. Table 2 illustrates how interest rates and features vary according to the type of credit product for customers, both secured and unsecured. Table 2. Comparison of Commonwealth Bank retail banking products Product Credit Type Interest rate Transaction al Debit MasterCard N/A Y N Prepaid MasterCard N/A Y N Variable home loan Fixed line Secured 5.14%* N N Low Rate credit card Revolving Unsecured 13.49% Y N Personal Loan Fixed line Unsecured From 14.77%* N N Personal Car Loan Fixed line Secured From 9.54%* N N Personal Overdraft Revolving Unsecured 16.60% Y N Low Fee credit card Revolving Unsecured 19.74% Y N Awards credit card Revolving Unsecured 20.24% Y Y *Comparison rate Rewards 6

8 The costs of providing credit cards to customers are driven by four key components: pricing the risk of customers failing to meet their payment obligations and our risk of non-recovery, which is relatively high for an unsecured type of credit; relatively high direct operating costs through developing and rolling out product features including travel insurance, security and fraud surveillance, managing millions of transactions daily; the cost of providing Awards programs; and the cost of funds. The cost of funds only contributes 22 per cent of total costs. Risk of Non Recovery As credit cards are unsecured lending, they are sensitive to market pressures and the economic environment, particularly the unemployment rate. The long term economic cycle is a key element of credit card pricing as credit card issuers must factor in long run economic forecasts and risk into the interest rate charged. As credit made available on credit cards is not provided for fixed periods and is continually available to a customer, credit providers need to ensure that credit is priced for both current and future risk, particularly the potential for rising unemployment through the economic cycle. This long term risk is accounted for in the headline interest rate and does not fluctuate in line with the RBA cash rate. Operational costs Credit card issuers incur significant ongoing servicing costs relative to other types of loans, especially compared to products such as home loans. Costs include issuing card plastics with chip and contactless technology and fraud prevention tools. Credit card issuing also results in significant paper and postage charges due to the requirement for monthly issuance of statements, unlike quarterly and bi-annual frequency required for other lending products. A number of Commonwealth Bank credit cards also include complimentary travel insurance. Loyalty costs Customers with an Awards card earn points for their everyday credit card spend and these points can then be converted into a reward of their choice. Commonwealth Bank has continuously invested in CommBank Awards to ensure customers get demonstrable value from the program. Over the past three years, CommBank Awards customers have benefitted from over $700 million in redemptions and ongoing innovation such as instant redemption at point of sale. Customers can redeem their points from multiple retailers across thousands of items, including: gift cards at a number of retailers, including Coles, Caltex, BP and Myer; cashback paid directly into their credit card account; credit card annual fee rebates; discounts off selected Commonwealth Bank insurance products; 7

9 cinema tickets; discounts off car rentals or magazine subscriptions; charity donations; products from our online catalogue including items such as homewares, kids toys, or the latest Apple products; and frequent flyer points with Qantas or Virgin airlines. Loyalty points are not earned, and therefore are not paid for, on low fee or low rate cards. Cost of funds While the RBA cash rate is a cost driver for all lending products, the correlation to credit card rates is substantially lower than other products. Funding costs for Commonwealth Bank credit cards comprise only 22 per cent of the overall cost base. There are a number of factors taken into account when considering headline interest rates, including the competitive landscape, cost of loyalty rewards, default rates, operational costs, the economic cycle and regulatory obligations. Regulatory changes In the last six years, the credit card industry has seen significant regulatory changes. These include stricter income verification for new accounts introduced in Regulation also included the requirement to obtain customer consent before issuing credit limit increase invitations, requirements for written notification when a customer exceeds their credit limit, higher standards for mandatory disclosures both prior to sale and on monthly statements, requirements regarding repayment allocations and the banning of certain exception fees (all introduced in 2011). While the industry has supported and continues to support these measures, they have added to the cost of providing credit cards. Additional regulation being proposed under the RBA s Review of Card Payments Regulation creates further uncertainty for issuers. 6. ATM Fees We note the Committee s interest in the pricing of withdrawals from ATMs. Since domestic direct charging was introduced in 2009 Commonwealth Bank s charge for domestic withdrawals and balance enquiry transactions by non-commonwealth Bank customers has remained at a cost of $2. This charge reflects a partial recovery of the cost of providing the 3,487 Commonwealth Bank ATMs 2 at 2,474 unique locations throughout Australia. In the 12 months to 30 June 2015 there were more than 189 million withdrawals made, with over 25 million of these being completed by non-commonwealth Bank customers. In addition there were over 2.4 million balance enquiries by these customers. While the total revenue from ATM fees averages $54m per annum, the total cost of providing the Commonwealth Bank ATM network exceeds $160m per annum. The revenue from ATM 2 As at 30 June

10 fees has also been declining in recent years, with trends showing more customers using EFTPOS and card payments than ATMs. Despite these trends Commonwealth Bank considers ATMs a core component of the way we interact with our customers, evidenced by the 2011 commitment to invest $80m in an ATM refresh program to be completed by March This program offers a range of benefits to all users including non-commonwealth Bank customers such as new devices delivering improved security features, greater functionality such as foreign language capability, as well as providing improved disability access through enabling audio functionality throughout the fleet. 9

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