Field Guide
Card issuing: launching a card program
06
Market and trends
4 min read · Chapter 6 of 10
Who holds the power
Power in a card program follows whoever can say no, and the bank says no most often.
- The sponsor bank approves every program and change, sets the interchange split, holds reserves and can terminate. Its regulator can freeze it, which freezes you. Scale buys some leverage back: The Bancorp's three largest partners bring it 59% of its fintech fees.
- The networks write the rules, publish the rates, approve designs and prepaid programs, and can block a BIN. In the US, Regulation II and merchant litigation are about the only outside limits on them.
- Regulators reach most programs through the bank: prior approvals, re-verification, lookbacks and forced exits. In 2026 they also started letting fintechs become banks in numbers.
- Processors own the timeouts, the fallbacks and the data, and on exit the old processor's cooperation decides between a BIN transfer and reissuing every card.
- Program managers own the customer, the brand, often the ledger and the data, and the largest move processing in-house.
- Apple decides whether a card can be tapped from an iPhone and charges for it; small issuers can't negotiate the fee.
- Merchants decide how online debit is routed, and since July 2023 they can send it to a cheaper network even on an exempt card.
- Card makers set lead times and minimum runs.
Tailwinds and headwinds
These are the forces I'd expect anyone running or supplying a card program to watch over the next couple of years. Each one helps some players and hurts others, and several move money from banks and processors toward the biggest programs and brands.
Tailwinds:
| What's changing | Who gains | Who loses |
|---|---|---|
| Big brands keep moving their card programs to the bank that pays most, and Apple's card, with about $20 billion of balances, is moving from Goldman Sachs to JPMorgan. | Big brands (Apple, Walmart, Delta); issuers that win the books (JPMorgan, Synchrony, American Express); Mastercard, which kept both Apple and Walmart | Issuers that lose or exit a program (Goldman Sachs, and Capital One with Walmart); smaller issuers that can't match the payments |
| More software platforms launch cards through issuing platforms instead of their own bank deals, and Marqeta's processed volume in the quarter to June 2026 was about a third higher than a year earlier. | Stripe, Adyen, Marqeta, Lithic, Highnote; the sponsor banks behind them, such as Sutton; CPI Card Group, through on-demand cards | Incumbent processors' share of new programs (FIS, Fiserv); banking-as-a-service middleware such as Synctera and Treasury Prime |
| Regulators are granting fintechs bank charters in numbers for the first time, with 29 applications cleared in 2026 by mid-September. | The largest programs (Nubank, Mercury, Revolut); core and processing vendors selling to new banks (FIS, Fiserv) | Sponsor banks whose biggest partners leave; processors, if the new bank builds its own |
| Federal oversight has eased, and several of the 2024 sponsor-bank orders have ended. | Sponsor banks reopening to new partners; banking-as-a-service middleware; new programs facing lighter due diligence | Cardholders, if controls slip; vendors selling compliance on urgency |
| Cards that spend stablecoin balances are small but growing fast, with Visa reporting spend on them up nearly 200% in a year. | Visa; Stripe, through Bridge; Lead Bank and Cross River, which settle in USDC with Visa | Cross-border fee pools, a little, at today's scale |
Headwinds:
| What's changing | Who gains | Who loses |
|---|---|---|
| Debit fees are under pressure from three sides: the Justice Department's suit against Visa, merchants routing online debit to cheaper networks, and the Durbin court cases. | Merchants; PIN networks (Star at Fiserv, NYCE at FIS, Pulse at Capital One), which puts Fiserv and FIS on both sides | Visa; interchange-funded programs such as Chime; exempt sponsor banks (The Bancorp, Pathward) |
| Credit card fees face a merchant settlement awaiting final approval that trims interchange, a push for a 10% interest-rate cap and a bill to give big banks' credit cards a second network. | Merchants; smaller networks, if the routing bill passes | Big credit issuers (JPMorgan, American Express, Synchrony, Citi, Capital One); Visa and Mastercard; brands paid from co-brand rewards |
| The largest programs leave their sponsor banks and processors once they're big enough to build their own, as Chime did with its processor in 2025. | The largest program managers (Chime, Block), which gain margin and leverage | Marqeta, Galileo (SoFi), The Bancorp, Sutton, Stride |
| Sponsor banks still face money-laundering orders and partner losses, such as Coastal's $69 million charge on one credit partner, so their bar for new programs stays high. | Large, well-capitalized sponsor banks without recent orders; embedded platforms that carry the compliance (Stripe, Adyen) | Small programs facing longer due diligence and higher reserves; banking-as-a-service middleware; credit partners, whose collateral terms tighten |
| If interest rates fall, the deposit income that many programs and their banks share falls with them. | Programs funded by interchange rather than balances | Sponsor banks and programs that share deposit income (The Bancorp, Pathward, Chime, Green Dot); payroll cards that live on float |
The one thing I'd watch is the Eighth Circuit's ruling in Corner Post, because it sets what debit interchange is worth to every exempt-bank program in this guide.