Credit One Bank’s mission is to offer consumers a tool in the form of a credit card that will help them improve their life circumstances. This document aims to explain the basics of Credit One Bank: who its customers are, why customers want a card, how customers view the value proposition, the bank’s regulatory framework, and the role the bank plays in the economy.
Credit One Bank is the nation’s largest OCC-regulated monoline primarily non-prime credit card bank. “Monoline” means that the bank’s only business is credit card issuance; it does not make other types of loans. “OCC-regulated” means that the business is overseen by the Office of the Comptroller of the Currency (OCC), an independent bureau of the U.S. Department of the Treasury which charters, regulates, and supervises all national banks. The OCC supervises these institutions in order to ensure that they “operate in a safe and sound manner, provide fair access to financial services, treat customers fairly, and comply with applicable laws and regulations.” Credit One Bank undergoes extensive annual exams to ensure compliance. “Primarily non-prime” means that the majority of Credit One Bank’s customers have credit scores below 660. This group includes individuals with no or limited credit history, poor credit history, variable or difficult-to-document income, or those who have had major credit problems. Approximately one third of the US population falls into the category of non-prime, and these consumers often face challenges in accessing traditional financing options.
Sherman Financial Group, a company founded by Benjamin Navarro, purchased Credit One Bank in 2005. At the time of purchase, the bank had roughly 200,000 credit cards outstanding and was having some issues with the OCC. Sherman stepped in and resolved the issues; and within the next few years, the bank became a “Highly Rated Institution” per the OCC, which it continues to be today. As of 2025, Credit One Bank has over 18 million active cards outstanding. It is the seventh largest issuer of Visa/Mastercard in the country, and has more recently added nearly 4 million American Express cards.
The majority of Credit One Bank’s credit cards are financed with lines of credit provided by a consortium of national financial institutions with household names, including money center banks as well as large insurance companies. Thirty-three lenders participate in its financing facility, many of whom have partnered with Credit One for almost 20 years.
Over half of Credit One Bank’s customers have either no credit card or just one credit card when they apply. Customers have an average FICO credit score of approximately 600 on a scale of 300 to 850, which places them in the category of “fair” or “poor” credit. However, its customers would not be considered “low income.” The average income of its customers is approximately $65,000, which is slightly above the national average. An even more relevant data point is the median income of customers, which is actually 35% greater than the national median. The average age of its customers is late 40’s.
It is critically important to understand that the universe of non-prime consumers is by no means a static subset of the population. Non-prime consumers become prime as they improve their credit scores, which is quite common. Conversely, prime consumers may become non-prime if they encounter financial difficulties, which is also common. Statistically, nationwide 20-25% of credit cards originated as non-prime become prime within one year, and 15-20% of prime originations become non-prime.
Part of Credit One’s responsibility is to assess how much credit consumers can handle so that they don’t become over-extended, and set their credit line accordingly. For the average customer today, the starting credit limit is $600. Title I, Section 109 of the Credit Card Accountability Responsibility and Disclosure Act of 2009 enacted by Congress “Requires a card issuer to consider the ability of the consumer to make required payments as a prerequisite to opening any consumer credit card account, or increasing any credit limit.” In practice this involves assessing each potential customer’s income and expenses to ensure the suitability and affordability of the particular credit card product offered.
To give a sense of the use of the card, the largest proportion of expenditures charged is for groceries and gas, and the top five merchants by dollars spent are Walmart, Amazon, Costco, Target and Home Depot. Customers charge on average $90 worth of goods and services to their cards each month, and they make payments to their cards averaging $110 each month. The majority of customers take their financial responsibility seriously; hence, approximately 85% of cardholders make their payment each month. Credit One customers also tend to be very active managers of their financial situation. Credit One has on average five interactions with each customer per month, primarily to check a balance.
First and foremost, owning a credit card provides customers with a critical payment vehicle, allowing them traditional access to the economy. In today’s world, a credit card is a necessity for safe online shopping, paying for gas at the pump, reserving a hotel room or rental car, making a restaurant reservation, booking an Uber ride, and so on.
In many instances though, credit cards become not just a convenience but also a necessity. A study conducted by the Federal Reserve showed that nearly 40% of Americans would not have the resources to cover a $400 emergency expense; and when asked how they would handle such an emergency, the most common response was to use a credit card and pay it off over time. Some challenges faced by Credit One customers include divorce, medical issues, job loss, death in the family, natural disasters, etc.
For consumers facing such circumstances, alternative sources of funds would be unattainably expensive and/or onerous, and would not offer the opportunity to build credit. Payday loans and pawn shop loans typically carry a 400% APR; and title loans carry a 300% APR and are secured by the borrower’s vehicle, meaning that it can be repossessed in the event of non-payment.
Owning a credit card also allows a consumer to establish or rebuild credit. As customers demonstrate their ability to manage credit and make payments on time, Credit One grants them increases to their credit line. For customers who have been with Credit One for more than five years, the average credit line is $1,500.
Building credit is important for several reasons. One, building credit allows consumers to establish a credit profile and thereby lower their borrowing costs. As an example, on an average net basis, Credit One customers experience a FICO credit score increase of 30 points within four years of acquiring a card. That alone leads to savings of $960 per year on a typical auto loan. And two, establishing credit leads to the ability to access additional credit including obtaining a mortgage to purchase a home. Within two to three years of card issuance, Credit One customers demonstrate a 20% increase in homeownership, a 34% increase in total credit available, and a 28% lower likelihood of charge-off.
In addition to the above, all Credit One customers receive the following benefits:
In exchange for all of the benefits outlined above, Credit One customers pay a market interest rate on balances; and for many customers, an annual fee which averages $6 to $8 per month (i.e., less than $100 per year).
As a point of comparison, Credit One’s monthly fee equates to less than half the cost of a standard Netflix subscription in 2025. Fee-based services or subscriptions are ubiquitous in today’s world, with monthly fees for all types of streaming services, apps, memberships and so on.
Evidence clearly shows that Credit One customers deem the cost of owning the card worth the benefits they receive. Specifically, Credit One’s average customer has been with the bank for over four years. Furthermore, 85% of Credit One’s customers would recommend the card to a friend. When asked about their loyalty to Credit One, the most common response of interviewees participating in market research is that Credit One provided them a card when no other institution would.
It’s also worth noting that in the rare event that customers change their mind about owning the card in the first 90 days, they may cancel at no cost with no impact on their credit.
As with any financial institution serving millions of customers, Credit One Bank receives its share of customer complaints from time to time. However, despite primarily serving a financially challenged customer base, the number of complaints is consistent with institutions of its size.
As with all national banks, Credit One Bank is extensively examined on an annual basis by the OCC. The OCC is considered to be the gold standard of financial regulators and is charged with regulating 1,200 financial institutions, including the largest banks in the country (JPMorgan Chase, Bank of America, Citigroup, Wells Fargo). Typically the annual exam takes between five and eight weeks; as an example, in 2024, Credit One had 14 regulators on site for six weeks, reviewing every aspect of the business. The OCC also requires Credit One Bank to be independently audited annually to ensure the Bank’s financial statements are in accordance with GAAP.
Credit One Bank has been designated by the OCC as a “Highly Rated Institution” for 19 years due to its sound financial structure, adherence to regulations, absence of consent orders and strong performance in meeting community credit needs. Credit One Bank has no Consent Orders outstanding and has not been subject to a Consent Order in over 15 years (for context, the OCC issued 411 Consent Orders in this timeframe). Consent Orders would be issued if the OCC found any violation of laws, rules or regulations; any unsafe or unsound practices; or any breach of fiduciary duty by the bank’s officers, directors, employees, controlling stockholders, or agents. Credit One Bank also has the OCC’s highest possible Community Reinvestment Act CRA rating of “Outstanding.” Institutions receiving this rating have an outstanding record of, and are leaders in, ascertaining and helping to meet the community’s credit needs, including low- and moderate-income neighborhoods. This is a highly favorable regulatory profile.
The OCC’s annual exam focuses on the following areas:
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP): In the annual UDAAP exam, the OCC examines the full scope of Credit One’s operations to ensure that it is offering, advertising and servicing its cards in a way that ensures transparency, promotes fair treatment and prevents exploitation. The OCC pays particular attention to subprime offerings, as it considers there to be a heightened risk for UDAAP. In simple terms, practices are considered “unfair” if they cause substantial unavoidable monetary harm to consumers and such harm is not outweighed by benefits to the consumer. For example, if a fee is not adequately disclosed, the consumer could not have made a reasonable choice to avoid such fee. Practices are considered “deceptive” if they involve a material representation, omission, act or practice that is likely to mislead a reasonable consumer. And finally, practices are considered “abusive” if they take unreasonable advantage of a consumer’s lack of understanding of (or interfere with the consumer’s ability to understand) the risks, costs or terms of the product.
Consumer Compliance: The examiners look to ensure that Credit One is compliant with a myriad of consumer laws and regulations, including sampling actual accounts for compliance. They review methods of managing compliance risk; the adequacy of compliance policies, procedures and controls; the quality of compliance staff; and the complaint process and level/type of complaints relative to the industry. Compliance laws and regulations applicable to the business include: Truth in Lending, Equal Credit Opportunity Act, UDAAP, Fair Lending, SCRA, MLA, BSA, OFAC, AML, and all applicable State Laws.
Capital: The examiners review Credit One’s financial statements to ensure that it is maintaining adequate capital in scenarios involving financial, liquidity, credit, reputation and regulatory risk.
Asset Quality: The examiners perform an in-depth analysis of how Credit One models, measures, monitors and reserves against credit losses to ensure the adequacy of its allowances.
Management: The examiners look at all aspects of its people and processes including quality of the executive management team, governance practices, risk management strategies, strategic planning practices, MIS tools and reports, audit practices, and adherence to Board-approved policies and procedures.
Earnings: The examiners study the level and quality of earnings to ensure the adequacy of the allowance for credit losses and level of capital, including an analysis of the internal budgeting process and external financial audit.
Liquidity: The examiners assess the level and quality of liquidity including funds management practices, operational cash flow, level of insured/non-insured deposits, liquidity monitoring and reporting, and contingency funding plan.
Sensitivity to Market Risk: The examiners evaluate Credit One’s level and quantity of interest rate risk and how it monitors, models and controls exposure to such risk.
Information Technology: The examiners review IT activities, checking for adequate audit practices, management of operational IT risk, and controls to ensure data confidentiality and integrity.
Community Reinvestment Act (CRA): Once every three years, the OCC assesses a national bank’s lending, investment and service practices to ensure that the bank is helping to meet the credit needs of its entire community, including low and moderate income neighborhoods. Any evidence of discriminatory or illegal credit practices would negatively affect the CRA rating.
Credit One card products have received numerous favorable reviews from Credit Karma, CNBC, Conde Nast Traveler and Forbes.
Forbes
Forbes claims over 60 years of combined experience among their editors, who they say are committed to providing unbiased ratings and information. They state that “We use data-driven methodologies to evaluate financial products and companies, so all are measured equally.”
In February 2025, Forbes rated the “Credit One Wander” card as the “Best travel card for fair credit” with five stars, stating that the card “does charge an annual fee, but it could be worth the cost for travelers thanks to its nearly unbeatable bonuses for travel-related spending.”
CNBC
CNBC Select seeks to provide comprehensive advice for consumers to make informed decisions with their money. According to their report, “Every credit card review is based on rigorous reporting by our team of expert writers and editors with extensive knowledge of credit card products,” and “To determine which credit cards offered the best value for people with poor credit, CNBC Select analyzed the most popular credit cards offered by banks, financial companies and credit unions that we determined to have requirements for poor credit scores. We compared each card’s range of features, including the annual fee, rewards programs, introductory and standard APRs, balance transfer fees, welcome bonuses and foreign transaction fees, as well as other factors such as required credit scores and customer reviews, when available.”
In March 2025, CNBC rated the “Credit One Platinum Visa for Rebuilding Credit” card as one of the “Best credit cards for scores of 580 and below” and “Best card for no security deposit.” This is a credit builder card that still allows customers to earn rewards on eligible gas and grocery purchases, monthly mobile phone, internet, cable, and satellite TV services.
In April 2025, CNBC rated the “Credit One Wander” card as one of the “Best travel cards for fair credit” and “Best for earning rewards.” The Credit One Bank Wander Card is designed to provide travel rewards for purchases on hotels, rental cars, dining and gas to customers with fair or average credit.
Credit Karma
As of April 2025, the “Credit One Platinum Visa for Rebuilding Credit” had the highest customer rating of the 5 most frequently reviewed cards on Credit Karma, beating out Chase Freedom, Amex Blue, and Citi Double Cash.
Conde Nast Traveler
In February 2024, Conde Nast Traveler rated the “Credit One X5” card as “Best card for fair credit,” stating that “Most credit-building cards do not offer any rewards; if they do, the rates are meager. The opportunity to earn five percent cash back, even with a reasonably low spending limit, is enticing.”
Credit One Bank customers are typical Americans who are either just beginning to establish a credit profile, or who have encountered a financial difficulty along the way. In fact, its customers typically expect to soon have their credit challenges behind them. Their beliefs are supported by data showing that in many cases financial hardships are transitory. Without businesses such as Credit One Bank and others that lend to the non-prime market, one third of US citizens would have no opportunity to own a card for emergencies, no card for living in an increasingly cashless society, and no chance to build or rebuild credit. In short, they would have no ability to participate in the modern economy.
Credit One believes these consumers deserve a chance and a choice to have a credit card and the opportunity to build or rebuild credit.
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