Campus Affinity Card Agreements Under the CARD Act: Portfolio Scale, Governance, and the Limits of Transparency

This study examines campus affinity card agreements under the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act, focusing on how portfolio size, new account openings, and institutional governance affect issuer payments. Using cross sectional data from 6145 issuer institution agreements reported to the Consumer Financial Protection Bureau (CFPB) in 2022, the analysis employs descriptive statistics, correlation tests, and multivariate regression models to identify predictors of payment volume. Results show that total open accounts strongly predict issuer payments, while new account openings exhibit a weak positive bivariate correlation but exert a modest negative effect in multivariate models once portfolio scale and institution type are controlled for. Foundations received the highest average issuer payments, followed by hybrid organizations and universities. This pattern reflects differences in governance structure, administrative capacity, and bargaining leverage. Transparency requirements under the CARD Act reveal broad patterns but omit incentive timing and interchange revenue, limiting full accountability. This is among the first large-scale empirical analyses of CFPB’s affinity card dataset, advancing understanding of equity in campus credit markets and offering policy relevant insights for regulators and administrators.