The largest credit card issuers are less likely than smaller banks and credit unions to charge a foreign transaction fee, but far more likely to charge for balance transfers, cash advances and an annual fee, according to the Consumer Financial Protection Bureau’s survey of 663 credit card plans as of December 31, 2025.
36.8% of plans from the 25 largest issuers charged a foreign transaction fee, against 71.9% of plans from smaller issuers. But where they did charge it, the big issuers’ median fee was 3% of the purchase, against 1% at smaller ones.
The gap ran the other way for the other fees. 79.3% of large-issuer plans charged a balance transfer fee (median 5% of the amount moved), against 28.5% of smaller-issuer plans (median 3%). 91.0% of large-issuer plans charged a cash advance fee, against 45.5%. 25.1% had an annual fee, with a median of $99, against 4.0% and $49 at smaller issuers.
Interest rates differed too. The median cash advance APR was 29.24% on large-issuer plans and 13.90% on smaller-issuer plans.
The comparison
| Fee or rate | Largest 25 issuers | Smaller banks and credit unions | All plans |
|---|---|---|---|
| Foreign transaction fee: share of plans charging it | 36.8% | 71.9% | 50.2% |
| Foreign transaction fee: median rate | 3% of the amount | 1% of the amount | 2% of the amount |
| Balance transfer fee: share of plans charging it | 79.3% | 28.5% | 59.9% |
| Balance transfer fee: median rate | 5% of the amount | 3% of the amount | 5% of the amount |
| Cash advance fee: share of plans charging it | 91.0% | 45.5% | 73.6% |
| Cash advance fee: median rate | 5% of the amount | 3% of the amount | 5% of the amount |
| Annual fee: share of plans charging it | 25.1% | 4.0% | 17.0% |
| Annual fee: median, where charged | $99 | $49 | $95 |
| Cash advance APR, median | 29.24% | 13.90% | 28.74% |
| Purchase APR, median | 26.99% | 14.50% | 24.49% |
| Plans in the survey | 410 | 253 | 663 |
Shares are of all plans in each group. Median fee rates are among plans that state a percentage fee, and the median annual fee is among plans that charge one. APRs are the median of each plan’s median APR, among plans that report one. The largest 25 issuers are the institutions the CFPB flags as top 25 issuers in the data. Smaller banks and credit unions are the other institutions in the survey, a sample rather than every small issuer.
What the survey is
The Terms of Credit Card Plans survey is a twice-yearly CFPB collection of the terms on general-purpose credit card plans. It reports the terms each plan offers, not what cardholders actually paid, and it does not weight plans by how many accounts they have. A plan with millions of cardholders counts the same as one with a few hundred. Late fees are covered on a separate page.
Source
Consumer Financial Protection Bureau, Terms of Credit Card Plans survey data, December 31, 2025 release, downloaded October 28, 2026. U.S. government data in the public domain. Shares, medians and group comparisons are our calculations. Our table is available under CC BY 4.0. Credit "My Credit Guide (mycreditguide.org)".
Steven Reynolds, "Credit Card Fees by Issuer Size," My Credit Guide, October 28, 2026, https://mycreditguide.org/data/credit-card-fees-by-issuer-size/.