Short Answer

Both the model and the market expect credit card rates will be capped in 2026, with no compelling evidence of mispricing.

1. Market Behavior & Drivers

This market has demonstrated a clear sideways trading pattern, with the probability of credit card rates being capped by 2027 consistently oscillating within a narrow 10-point range. The price has established a support level around 9.0% and a resistance level at 19.0%. Over its history, the market has not sustained a breakout in either direction, suggesting a lack of a strong, directional consensus among participants. The current price of 17.0% is near the top of this historical range, indicating a recent increase in perceived probability, but it remains within the established channel. Total volume is moderate at 15,474 contracts, and the sample data indicates periods of very low or zero trading activity, which can suggest that price movements sometimes occur without strong market-wide conviction.
The most significant price movement was a sharp 8.0 percentage point drop on April 24, 2026, when the price fell from its peak of 19.0% to 11.0%. The available context does not provide a specific news event or development to explain this sudden decrease in perceived probability. However, the price subsequently rebounded to 17.0% by April 29th, erasing most of the loss from that single event. This quick recovery suggests that either the information driving the drop was quickly discounted by the market or that traders viewed the 11.0% level as an attractive entry point, stepping in to buy contracts and push the price back up toward its resistance level.
Overall, market sentiment appears uncertain but stable, assigning a consistently low, sub-20% probability to the event's occurrence. The price action reflects a market that is largely in a holding pattern, reacting to minor shifts in information but awaiting a major catalyst to break out of its long-term trading range. The sideways trend and the sharp but temporary drop indicate that while traders are sensitive to new information, there is an underlying equilibrium and a lack of conviction that the odds will change dramatically before the resolution date.
  • Senator Tim Scott is a likely chair for Senate Banking Committee.
  • CFPB may explore regulating credit card interest rates under 2025 administration.
  • Specific 2025 credit card lobbying expenditure data remains unavailable.
  • Federal Reserve offers qualitative loan assessments, not quantitative delinquency rate predictions.
  • The market saw an 8 percentage point probability drop on April 24, 2026.

Who Wins and Why

Outcome Market Model Why
Before 2027 17.0% 12.1% A potential Trump administration could pursue populist policies like credit card rate caps.

2. Price Chart

Historical Price (Probability)

Outcome probability
Date

3. Significant Price Movements

Notable price changes detected in the chart, along with research into what caused each movement.

📉 April 24, 2026: 8.0pp drop

Price decreased from 19.0% to 11.0%

Outcome: Before 2027

What happened: No supporting research available for this anomaly.

4. Market Data

Contract Snapshot

This market resolves to "Yes" if the U.S. federal government takes action to cap annual credit card interest rates before January 1, 2027, with the action not needing to be effective by that date. Conversely, it resolves to "No" if no such action occurs by the deadline. The market will close early if the event happens, otherwise it closes by January 1, 2027, at 10:00 AM EST, with projected payout 30 minutes after closing.

Available Contracts

Market options and current pricing

Outcome bucket Yes (price) No (price) Last trade probability
Before 2027 $0.16 $0.86 17%

Market Discussion

Traders are split on whether credit card rates will be capped by 2027, with many expressing significant frustration over the market's vague rules, particularly regarding whether an executive order or only a bill passed by Congress would qualify as "government action." Some foresee a cap, potentially between 15-25%, believing that current proposals qualify as "action." Others argue a cap is unlikely due to political opposition from Republican leaders and the Trump administration, and the belief that only Congress possesses the authority to implement such a change.

5. Trust Index

Octagon Trust Index Kalshi 66 Caution

Order book is critically thin.

Primary risk· Trade quality

How it adds up
Integrity80% of score82Good
Trade quality20% of score4Avoid

Includes the cost to trade: a $1,000 order can't be filled here because the order book is too thin.

Trust score66Caution

Weighted blend with hard caps — a critically weak safety pillar, or a severe trading anomaly, caps the total regardless of the rest. Full methodology · About the Trust Index

Trust profile
Integrity4 screens run · 6 don't apply
Market integrity
77Good

Outcome is hard to influence

Thin-volume movesTrade signals · high confidence

“Before 2027” made a large jump with almost no trading behind it.

Screened clean
Large tradesNo single trade dominates the tape. Clear
Size patternsNo distribution read Clear
2 screens not run
Outcome control · doesn't apply to this market type
Thin-leg conviction · doesn't apply to this market type
Info fairness
80Good

Structural prior — no screens apply

No suspicious activity on any screen

Screened clean
Information exposureNo concentrated group can know the outcome materially early. Clear
4 screens not run
Move vs. catalyst · doesn't apply to this market type
Longshot repricing · doesn't apply to this market type
Pre-broadcast certainty · doesn't apply to this market type
Cross-venue timing · doesn't apply to this market type
Resolution quality
92Strong

Resolution mechanism is dependable

No suspicious activity on any screen

Resolution rules read: Clear

Liquidity
4Very thin

Hard to fill near the screen price

1 contract

Before 20274
Very thin · low confidence

Light recent trading — size may not fill near the screen price.

Move quality
65Mostly confirmed

Most moves carried real volume

1 contract

Before 202765
Mostly confirmed · medium confidence

Volume is light/neutral for the move over 24h

Rule clarity
100Clear

Counts toward Resolution quality, not here

1 contract

Before 2027100
Clear · high confidence

All checks pass

objective outcome · Clearofficial source · Cleartime boundary · Clear
Trade quality
4Avoid

Order book is critically thin

Thin market — entering or exiting at fair value will be difficult.

Outcome quality 4 (notional-weighted)

$100 order: 1.5c slippage (~39% of a 3.8c contract)

$1,000 order: book too thin to fill

$10,000 order: book too thin to fill

Before 20274Market scoreLiquidity4Move quality65Rule clarity100
Why 4
Liquidity
4 · Very thin · low confidence

Light recent trading — size may not fill near the screen price.

Move quality
65 · Mostly confirmed · medium confidence

Volume is light/neutral for the move over 24h

Rule clarity
100 · Clear · high confidence

All checks pass

objective outcome · Clearofficial source · Cleartime boundary · Clear

underwriting_v1.4 · computed Sep 23, 2026

6. Who Will Chair Banking Committees and What Are Their Priorities?

Senate Banking Committee Chair (119th)Senator Tim Scott [1]
House Financial Services Committee Chair (119th)Representative French Hill [2]
Stance on Federal Interest Rate CapsPriorities suggest opposition, neither sponsored VCFCA [1]
Prospective chairs for 2025-2026 Congress outline their financial priorities. Senator Tim Scott is the likely chair for the Senate Banking Committee, with his legislative priorities focusing on reining in the regulatory state, promoting capital formation and economic growth, increasing housing affordability, and financial inclusion [1]. He has also co-sponsored legislation to modernize credit scoring by allowing alternative data [3]. Representative French Hill is expected to chair the House Financial Services Committee, emphasizing priorities such as promoting growth, stability, and innovation in capital markets, providing regulatory relief, and protecting consumers [2]. Representative Hill has also sponsored the Main Street Capital Access Act to simplify capital raising for small businesses [4].
Neither prospective chair has supported the Veterans and Consumers Fair Credit Act. Specifically, Senator Tim Scott and Representative French Hill have not sponsored the Veterans and Consumers Fair Credit Act (VCFCA) or similar bills [5]. The VCFCA proposes a national interest rate cap of 36% on most loans. Their publicly articulated legislative priorities suggest a general opposition to increased federal regulation on financial products, including the imposition of federal interest rate caps. This is evident in Senator Scott's aim to "rein in the regulatory state" [1] and Representative Hill's focus on "providing regulatory relief" [2].
Sources (5)
  1. 1Scott Announces Banking Committee Priorities for the 119th Congress | Community Development Bankers Associationcdbanks.org
  2. 2Chairman Hill's Opening Statement for First Markup of 119th Congress | U.S. House Committee on Financial Servicesfinancialservices.house.gov
  3. 3Scott, Manchin Reintroduce Bill to Increase Credit Access and Financial Inclusion | United States Committee on Banking, Housing, and Urban Affairsbanking.senate.gov
  4. 4Main Street Capital Access Act (H.R. 6955) - GovTrack.usgovtrack.us
  5. 5Text of S. 2508 (117th): Veterans and Consumers Fair Credit Act (Introduced version) - GovTrack.usgovtrack.us

7. Is 2025 Lobbying Expenditure Data Available for Credit Card Topics?

2025 Lobbying Data AvailabilityNot possible to calculate ratio due to absence of specific 2025 LDA filings [1].
Available LDA FilingsFrom Q3 and Q2 2024, not 2025 [1].
Other Research SourcesAnalytical reports and articles, not 2025 lobbying data [2].
The exact ratio of lobbying expenditures for 2025 cannot be calculated. It is not possible to determine the precise ratio of lobbying expenditures by the top five banking industry groups versus the top five consumer advocacy groups that mention 'credit card APR,' 'usury,' or 'interchange' in their 2025 quarterly Lobbying Disclosure Act (LDA) filings. This is primarily due to the absence of specific 2025 quarterly LDA filings needed to extract this detailed data.
Current filings are from 2024, not comprehensive for 2025. The available LDA disclosure forms found are for the 3rd and 2nd quarters of 2024, rather than 2025, and represent specific entities such as COBANK, ACB and Wells Fargo & Company [1]. While these filings do mention terms like 'Credit/Debit Card Interchange' and 'interchange,' they do not collectively represent the top five banking industry groups or any consumer advocacy groups for the specified 2025 period. Other sources provided were analytical reports and articles discussing topics like credit card interest rates and potential caps, not actual 2025 lobbying expenditure data [2].
Comprehensive 2025 LDA filings are essential for accurate analysis. To accurately determine the requested ratio, access to comprehensive 2025 quarterly LDA filings for a broader range of both banking industry groups and consumer advocacy organizations, with specific keyword tracking, would be necessary through the LDA.gov portal [3].
Sources (3)
  1. 1LD-2 Disclosure Formlda.senate.gov
  2. 2Banks Respond to Proposed Cap on Credit Card Interest Rates - Bank Policy Institutebpi.com
  3. 3Home | LDA.govlda.senate.gov

8. Could CFPB Regulate Credit Card Interest Rates in 2025?

Potential RegulatorConsumer Financial Protection Bureau (CFPB) [1]
Primary Legal BasisProhibition of "abusive" acts under CFPA [1, p [1]. 1-2; 7, p [2]. 1-2] [3]
Less Likely RegulatorOffice of the Comptroller of the Currency (OCC) [4]
The Consumer Financial Protection Bureau (CFPB) may explore regulating credit card rates. Under a 2025 presidential administration, the CFPB could potentially issue an Advance Notice of Proposed Rulemaking (ANPRM) to examine its authority to regulate "excessive" credit card rates [1]. The agency has previously regulated credit card terms, such as late fees, demonstrating its willingness to use existing authority to address problematic terms [5]. The primary legal basis for such an exploration would be the CFPB's power under the Consumer Financial Protection Act (CFPA) to prevent "abusive" acts or practices in consumer financial products [1, p. 1-2; 7, p. 1-2]. Political interest, for instance, from a potential Trump administration concerning credit card rate caps, could prompt the CFPB to initiate this exploratory process [3].
However, federal interest rate caps face significant legal hurdles, especially due to existing legal precedents. Imposing general interest rate caps federally faces substantial legal challenges, largely because of the Supreme Court's 1978 Marquette decision, which allows national banks to apply their home state's usury rates, thereby limiting federal caps without new congressional action [1, p. 2-3; 7, p. 2-3; 8, p. 1]. While the CFPB might explore its "abusive" authority, it would likely encounter considerable legal obstacles in establishing a binding rate cap [1]. The Office of the Comptroller of the Currency (OCC), primarily overseeing national bank safety and soundness, is less likely to initiate an ANPRM on broad consumer protection policy like interest rate caps compared to the CFPB [4]. Therefore, any ANPRM exploring this specific regulatory authority would most probably originate from the CFPB, driven by political objectives and its CFPA mandate, despite the inherent legal difficulties in establishing a binding rate cap without specific new legislation.
Sources (5)
  1. 1https://www.congress.gov/crs_external_products/IF/PDF/IF12861/IF12861.4.pdfcongress.gov
  2. 2https://bpi.com/wp-content/uploads/2025/05/The-Potential-Adverse-Consequences-of-a-Credit-Card-Interest-Rate_Cap_note.pdfbpi.com
  3. 3Trump credit card rate cap has unclear path, 'devastating' riskscnbc.com
  4. 4https://www.occ.treas.gov/publications-and-resources/publications/comptrollers-handbook/files/credit-card-lending/pub-ch-credit-card.pdfocc.treas.gov
  5. 5https://files.consumerfinance.gov/f/documents/cfpb_credit-card-penalty-fees-nprm_2023-01.pdffiles.consumerfinance.gov

9. What Key Bills Did the House Rules Committee Advance?

NDAA AdvancementAdvanced by House Rules Committee [1]
Other Bills ConsideredH.R. 3838, H.R. 6387, H.R. 1 [2]
Financial Services Committee ActivityHeld markups on various measures [3]
The House Rules Committee considered several significant legislative vehicles for the 119th Congress. The committee advanced the National Defense Authorization Act (NDAA), which is a typically substantial legislative item [1]. Other bills considered included H.R. 3838, known as the "Streamlining Procurement for Effective Execution" [2], H.R. 6387, the "FIRE Act" [4], and H.R. 1, titled the "One Big Beautiful Bill Act" [5]. However, the available research does not indicate whether any of these legislative vehicles were designated as an 'open rule' by the committee.
Information on member voting records on financial services amendments remains unavailable. The research does not provide specific details on individual appointed House Rules Committee members or their voting histories concerning the allowance of financial services amendments. While the U.S. House Committee on Financial Services did hold markups on various measures [3], these actions relate to the Financial Services Committee's proceedings, not the specific voting records of House Rules Committee members on rule designations for amendments.
Sources (5)
  1. 1House Rules Committee advances NDAAdigital-release.thehill.com
  2. 2H.R. 3838 - Streamlining Procurement for Effective Execution | House of Representatives Committee on Rulesrules.house.gov
  3. 3Markup of Various Measures | U.S. House Committee on Financial Servicesrepublicans-financialservices.house.gov
  4. 4H.R. 6387 – FIRE Act | House of Representatives Committee on Rulesrules.house.gov
  5. 5H.R. 1 - One Big Beautiful Bill Act | House of Representatives Committee on Rulesrules.house.gov

10. Will National Credit Card Delinquency Rates Breach Past Highs?

Post-2008 Delinquency Peak3.17% in Q1 2010 (all commercial banks) [1]
SLOOS Delinquency ForecastNo numerical consensus forecast provided [2]
Current Delinquency Rate TrendRising above pre-pandemic levels since second half of 2021 [3]
The Federal Reserve's Senior Loan Officer Opinion Survey (SLOOS) primarily provides qualitative assessments of lending standards and loan demand, not specific numerical forecasts for national credit card delinquency rates [2]. The survey, therefore, does not offer a numerical consensus forecast for the 3-month average of the national credit card delinquency rate for Q4 2025 or any other particular future period [4].
Delinquency rates are rising but not forecast to breach post-2008 highs. The post-2008 peak for the delinquency rate on credit card loans from all commercial banks stood at 3.17% in Q1 2010 [1]. Although the precise national credit card delinquency rate for Q4 2025 is not directly presented in the available research [5], Federal Reserve analyses indicate that credit card delinquency rates have been rising from historic lows since the latter half of 2021 and currently exceed pre-pandemic levels [3]. However, the provided sources do not explicitly project these trends to breach the 3.17% post-2008 high [1]. External forecasts, such as TransUnion's 2026 outlook, anticipate "moderate credit card balance growth and stable delinquency rates" for the forthcoming year [6]. Furthermore, the research does not link current delinquency trends to any specific public pressure for legislative action.
Sources (6)
  1. 1Delinquency Rate on Credit Card Loans, All Commercial Banks (DRCCLACBS) | FRED | St. Louis Fedfred.stlouisfed.org
  2. 2The Fed - Senior Loan Officer Opinion Survey on Bank Lending Practicesfederalreserve.gov
  3. 3The Fed - A Note on Recent Dynamics of Consumer Delinquency Ratesfederalreserve.gov
  4. 4The Fed - The January 2026 Senior Loan Officer Opinion Survey on Bank Lending Practices, Table 1federalreserve.gov
  5. 5Q4 2025, Delinquencies: Delinquency Rates for All Banks | FRED | St. Louis Fedfred.stlouisfed.org
  6. 6TransUnion 2026 Outlook: Moderate Credit Card Balanceglobenewswire.com