120 BUREAU OF CONSUMER FINANCIAL PROTECTION — CONSUMER CREDIT CARD MARKET REPORT
Unlike the Great Recession, cardholders have largely avoided delinquency and charge off, as of
the time of this report writing. As noted above in Section 2, overall rates of delinquency and
charge-off declined significantly following the onset of COVID-19.
218
Several factors likely played
a role in this development, such as extensive public aid to consumers (including Economic
Impact Payments, increased unemployment insurance payments and expanded unemployment
insurance coverage, and the Paycheck Protection Program), government-mandated forbearance
on certain types of loans (including some mortgages and student loans), an increase in
charitable giving,
219
state and federal moratoria and other limitations on tenant eviction, and
other forbearance and relief voluntarily offered by financial institutions, as well as the recovery
in employment and income over the latter half of 2020. However, much of that aid may not have
made its way to struggling consumers with credit card debts until weeks or months after those
consumers experienced a sudden and unexpected loss in income.
220
As noted earlier, surveyed
issuers made payment deferral widely and rapidly available after the onset of the pandemic. This
may have served to tide many consumers over until they could access those supports and
programs outlined above.
218
See Sections 2.5 and 2.6.
219
See, e.g., AFP Foundation for Philanthropy, FEP Reports, https://afpglobal.org/fepreports (last visited Aug. 18,
2021).
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To take one such aid program as an example, the IRS reported distributing nearly 90 million Economic Impact
Payments totaling over $160 billion between the passage of the CARES Act on March 27, 2020 and April 17, 2020.
See IRS, Treasury, IRS deliver 89.5 million Economic Impact Payments in first three weeks, release state-by-state
Economic Impact Payment figures (Apr. 28, 2020),
https://www.irs.gov/newsroom/treasury-i rs-deliver-89-point-
5-million-economic-impact-payments-in-first-three-weeks-release-state-by-state-economic-impact-payment-
figures. Those figures reached approximately 127 million and $216 billion, respectively, by May 8
th
, and 159 million
and $267 billion by June 3
rd
, 2020, with distribution continuing after that point as well. See IRS, Treasury, IRS
release latest state-by-state Economic Impact Payment figures (May 8, 2020),
https://www.irs.gov/newsroom/treasury-i rs-release-l atest-state-by-state-economic-impact-payment-figures and
see also IRS, 159 million Economic Impact Payments processed; Low-income people and others who aren’t
required to file tax returns can quickly register for payment with IRS Non-Filers tool (Jun, 3, 2020),
https://www.irs.gov/newsroom/159-million-economic-i mp act-payments-processed-low-income-people-and-
others-who-arent-required-to-file-tax-returns-can-quickly-register-for-payment-with-irs-non-filers-tool. As noted
earlier in this subsection, the economic deterioration brought on by COVID-19 was extremely swift, with 20 million
jobs vanishing by the end of April 2020. It is therefore plausible that at least some consumers with credit card debt
who experienced a sudden loss of job or other income in late March or early April of 2020 may not have received
their Economic Impact Payments until several months later, highlighting the potential impact to those consumers of
being able to defer their credit card payments during that intervening period.