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CHI Company Investigation · Finance

Goldman Sachs

The Consumer Bank Goldman Built — and Then Dismantled

Marcus · Apple Card · Apple Savings · GM card · GreenSky · Marcus Invest
Twelve research streams · Disposition: narrow investigation only · No numerical score assigned

Goldman’s consumer products were often better for customers than the market norm. Execution failures, and then a strategic retreat, moved millions of those customers to products, servicers and issuers they had not chosen.

This is not primarily an extraction story. The research found no fee layering, no repricing of captive customers and no charge introduced on a free feature. It found a flagship card launched with a disputes system Goldman’s board had been told was not fully ready, and a consumer business taken apart product by product while the deposits it had gathered were kept. This page sets out what the record establishes, what it does not, and where responsibility is shared.

$45mCFPB penalty on Goldman over Apple Card, plus $19.8m redress (2024)
7Consumer products exited, sold or transferred, 2021–2026
$228bnConsumer deposits Goldman kept, June 2026
~$6.3bnPlatform Solutions pre-tax losses, 2021–2024, as first reported
● Estimated read 25 min
Editorial illustration of a lit office tower bearing the Goldman Sachs name at night

The products What customers were offered

Fee-free by design, and priced near the top of the market.

Apple Card launched with no annual, late, foreign-transaction or over-limit fees, and still has none. Marcus loans carried no origination, late or prepayment fees. Marcus savings had no fees and no minimum, and paid well above the national average for most of a decade. Apple Savings opened at 4.15% APY, which Apple described as more than ten times the national average.A1P13P12A2

No card fees No loan fees No savings fees Above-market deposit rates

The relationship What happened to it

Launched before it was ready, then dismantled product by product.

Apple Card went live after Goldman’s board was told its disputes system was “not fully ready”. Between 2021 and 2026 Goldman closed, sold or transferred every consumer product it had built or bought except savings, moving borrowers, cardholders and investors to SST, Betterment, Uncapped, Barclays, a Sixth Street-led group and, by about early 2028, JPMorgan Chase.R1G8G1

Disputes system not ready Seven exits Unchosen counterparties Deposits retained

Both columns describe the same consumer business. The documented problem is not that Goldman charged its customers too much. It is execution, servicing capacity and strategic continuity: what happened to customers recruited into products Goldman later decided it no longer wanted to operate.

Executive finding

Goldman built a consumer bank on unusually generous terms, launched its flagship card before its servicing was ready, then dismantled almost everything except the deposits.

The Goldman Sachs Group entered retail finance in 2016 through Marcus and, from 2019, as issuer of Apple Card. CHI’s research phase ran twelve streams over regulatory orders, SEC filings, earnings transcripts, product documentation, court records, the CFPB complaint database and financial journalism, and closed on 25 September 2026. The research also covered Goldman’s institutional businesses; this page concerns the consumer businesses, where the disposition applies.

The products were consumer-friendly.

A fee-free card, fee-free loans and fee-free savings, with deposit rates often near the top of the market. Apple Card ranked first in its J.D. Power segment from 2021 to 2024.

Apple Card launched before it was ready.

A regulatory finding: the board was told the disputes system was “not fully ready”. About 157,000 acknowledgments and 145,000 resolution letters were later sent late.

Responsibility is shared with Apple.

The CFPB separately found that Apple’s own dispute form failed to forward tens of thousands of disputes to Goldman. Apple paid a $25m penalty.

Almost everything but deposits was exited.

Seven consumer exits between 2021 and 2026. Over the same years consumer deposits grew to $228bn.

The losses fell on Goldman.

About $6.3bn of pre-tax losses in 2021–2024 in the unit that held the card programmes. The usual hostility motive, harm turned into margin, is absent.

The sequence the record documents2016–2028 · six overlapping stages
  1. 01 · Build2016–2022

    A consumer bank from scratch

    Marcus loans and savings, Apple Card, the GM card and GreenSky. Investor Day 2020 targets: $125bn+ deposits, $20bn+ loans and cards.

    Fact T1
  2. 02 · Service failure2019–2021

    Apple Card disputes

    Dispute handling failed at scale. The CFPB said hundreds of thousands of Apple Card users were affected.

    Regulatory finding T1
  3. 03 · Losses2021–2024

    A loss in every year

    About $6.3bn of pre-tax losses in Platform Solutions, as first reported. “We tried to do too much too quickly,” its CEO said in 2023.

    Fact T1
  4. 04 · Retreat2021–2026

    Seven exits

    Clarity Money, personal loans, GreenSky, Marcus Invest, business credit, the GM card and Apple Card.

    Fact T1
  5. 05 · Transitions2021–2028

    Unchosen counterparties

    SST, Betterment, Uncapped, Barclays and Chase. Most accounts and terms carried over; Clarity Money simply closed.

    Fact T1
  6. 06 · Deposits retained2026

    Marcus and Apple Savings

    $228bn of consumer deposits, about 41% of Goldman’s total deposits at June 2026.

    Fact T1

Order, not a single chain of cause. The stages happened in this order and overlap in time, but the arrows do not mean each caused the next. The CFPB ties the dispute failures to the 2019 launch decision, not to later cost-cutting. Goldman presented each exit as loss-stopping. Analytical inference

How to read this page

The research labels every material claim by the kind of evidence behind it and by source tier. This page keeps those labels where the distinction matters, and never presents a lower-tier source as fact.

FactEstablished from a filing, product document, official release or database.
Regulatory findingA regulator’s finding in an order or report. Goldman neither admitted nor denied the CFPB’s.
Company statementGoldman’s or a partner’s own words, not independently verified.
Customer reportA consumer’s account, from press reporting or review sites. Never treated as fact.
ReportedPress-reported and not adjudicated, often relayed from an original that could not be reached.
Analytical inferenceCHI’s reading of the evidence, stated as such and never used to assign motive.
UnresolvedThe evidence does not settle it. The page leaves it unsettled.
T1Filings, regulatory orders, court records and official company or partner documents.
T2Major financial journalism, including reporting relayed by secondary outlets.
T3Forums, review sites and aggregators. Used only as labelled customer reports.

The contradiction

Goldman does not fit the hostile-bank story. Its consumer products were built without the fees that story depends on.

Customer-hostile retail finance usually earns its margin from fees and from repricing customers who are slow to leave. Goldman’s consumer products were built without those levers, and the research found no case of one being added later.

The levers retail finance commonly uses, and what Goldman did with them
ProductCommon leverGoldman’s terms at launchAt research close
Apple CardAnnual, late, foreign-transaction and over-limit feesNone (August 2019)A1None. The fee structure is unchanged as of July 2026.A3
Marcus personal loansOrigination, late and prepayment feesNone, plus a reward letting on-time payers skip a month without interestP13No new loans since January 2023. Remaining loans kept their original terms.G8
Marcus savingsMonthly fees, minimum balances, teaser ratesNo fees, no minimum“No fees. No minimum deposit.” 3.50% APY (September 2026)G9
Apple SavingsIntroductory rate, then lag4.15% APY, no fees or minimums (April 2023)A23.5% APY (September 2026, medium confidence)P16
3.50%Marcus savings APY, against a 0.37% national average (March 2026)Fact · T2
#1Apple Card in its J.D. Power satisfaction segment in 2021, 2022, 2023 and 2024Fact · T1
#3Apple Card’s J.D. Power ranking in 2025, the first year it fellFact · T1
0Fees introduced on any Goldman consumer product, 2016–2026Research finding

The investigation did not find a systematic consumer fee-extraction strategy.

Two things that could look like repricing were examined and set aside. Apple Card’s APR range moved from 12.99–23.99% at launch to 17.49–27.74% by July 2026, in line with contractual prime-rate indexing over a rate cycle. And for about three weeks in April–May 2023 Apple Savings paid 4.15% while Marcus paid 3.90%; Goldman raised Marcus to match around 9 May 2023, citing the risk that customers would leave rather than fairness.A3P14 Analytical inference

Apple Card · launch before ready

Goldman’s board was told the disputes system was “not fully ready.” Apple Card launched anyway.

The CFPB’s October 2024 consent order against Goldman Sachs Bank USA is the strongest customer-facing evidence in the record. Everything in this section labelled a regulatory finding comes from that order or from the CFPB’s separate order against Apple. Goldman neither admitted nor denied the findings.

  1. December 2017 · the agreement

    Under the Apple–Goldman agreement, Goldman would extend the credit and investigate consumer disputes; Apple designed the interfaces and advertising. Apple could seek “$25 million in liquidated damages for each 90-day delay caused by Goldman.”R1 Regulatory finding T1

  2. August 2019 · the warning

    An assessment to Goldman’s board noted that the disputes system was “not fully ready” due to technological issues. Banking Dive’s summary of the order says the board learned of it four days before launch. The order also cites “tight timelines” and Goldman’s first large-scale outsourcing of contact-centre operations.R1P1 Regulatory finding T1

  3. 20 August 2019 · launch

    Apple Card launched to all US customers with no fees and 1–3% Daily Cash.A1 Fact T1

  4. August 2019 – December 2021 · the failures

    The period in which the CFPB found dispute notices sent late or answered inadequately. Separately, from December 2019 to at least July 2020, Apple Card Monthly Installments were marketed in ways that implied purchases were automatically interest-free when customers in fact had to opt in at checkout.R1R2 Regulatory finding T1

  5. 23 October 2024 · the orders

    Goldman: a $45m civil penalty, at least $19.8m in redress, and a requirement to give the CFPB a compliance plan at least 90 days before launching any new consumer credit card. Apple: a $25m penalty.R1R2 Regulatory finding T1

  6. 22 September 2025 · one order closes

    The CFPB terminated Apple’s order early. Goldman’s was still listed as open at research close; whether the compliance-plan requirement remains in force is not settled by Goldman’s filings.R4 Unresolved

What the CFPB found Goldman did

~157,000Acknowledgment notices not sent within 30 days, as Regulation Z requiresRegulatory finding · para. 19
~145,000Resolution letters not sent within 90 daysRegulatory finding · para. 21
~167,000Billing-error notices that received inadequate responsesRegulatory finding · para. 23
HundredsAdverse credit-bureau reports on amounts still under disputeRegulatory finding · para. 27
ThousandsAccounts charged interest by customers who believed their purchases were in interest-free Monthly InstallmentsRegulatory finding · para. 50
10,000+Refunds applied to installment balances instead of the current balance, producing additional interestRegulatory finding · para. 58

The order also found that Goldman “failed to conduct reasonable investigations of Billing Errors before determining that no Billing Error occurred”, and that in unauthorized-use claims it held consumers liable for disputed amounts without conducting a reasonable investigation. The CFPB’s announcement said the violations affected “hundreds of thousands of Apple Card users.”R1R4

“[The board] made the business decision to go forward anyway, since Apple negotiated a provision that allowed them to penalize Goldman $25 million for every 90 days of delay.”Rohit Chopra, CFPB Director, prepared remarks, 23 October 2024 · Regulatory statement · T1R3
“We worked diligently to address certain technological and operational challenges that we experienced after launch and have already handled them with impacted customers.”Goldman Sachs spokesman, October 2024 · Company statement · T2. Goldman also called Apple Card “one of the most consumer-friendly credit cards that has ever been offered.”P15
After the order: CFPB complaints naming Goldman Sachs Bank USAAll products · 2020 – Sep 2026
All complaints“Problem with a purchase shown on your statement” (disputes)

Source: CFPB complaint database.R6 These are unverified consumer submissions. The database does not separate Apple Card from Marcus or the GM card, and no peer-adjusted rate was computed, so CHI draws no conclusion about prevalence. Disputes have been the largest single issue every year since 2021, and 2026 had passed the full-year 2025 count by September. Two facts weigh the other way: Goldman answered 99.8% of complaints on time, and gave monetary or other relief on 38% of 2025 complaints, the highest share among five peer issuers. Whether the post-2024 rise reflects servicing during the wind-down or a maturing card book is Unresolved

Attribution

Apple also matters. The regulator divided responsibility, and so does this page.

Apple designed Apple Card’s interfaces, marketing and dispute-intake screens. Goldman issued the card and held the legal duty to investigate the disputes it received. The CFPB issued separate orders against each company. Only distinctions supported by those orders, or labelled as reporting, appear below.

Goldman Sachs Bank USA

Goldman’s responsibility

Penalty $45m · redress $19.8m

  • Launching with a disputes system its board had been told was not fully ready, and outsourcing contact-centre operations at scale for the first time.
    Regulatory finding T1
  • Late and inadequate handling of the disputes it received, and holding customers liable without reasonable investigation.
    Regulatory finding T1
  • Adverse credit reports on amounts still under dispute.
    Regulatory finding T1
  • Misapplying 10,000+ refunds to installment balances.
    Regulatory finding T1

Outside the CFPB order

  • 2023 Apple Savings withdrawal holds, from Goldman’s own fraud and anti-money-laundering controls.
    Customer report T2
  • Customer-service deficiencies and a six-month wait before appealing credit terms, since removed.
    NYDFS finding T1
Both companies

Shared or system responsibility

Findings made in both orders, or joint by design

  • Installment marketing that implied purchases were automatically interest-free. The CFPB made findings against both companies.
    Regulatory finding T1
  • The launch decision. Goldman’s board made it, under a delay penalty Apple had negotiated.
    Regulatory finding T1
  • The seam itself. The customer’s first point of contact for a dispute sat under Apple’s design control; the duty to investigate sat with Goldman.
    Analytical inference
  • Remediation: a reported “second chance” to re-dispute transactions, and $100 goodwill credits after the 2023 savings delays.
    Reported T2
Apple Inc.

Apple’s responsibility

Penalty $25m · order terminated early, September 2025

  • Lost disputes. From June 2020, Apple’s “Report an Issue” form failed to send tens of thousands of billing-error notices to Goldman. Neither company investigated them.
    Regulatory finding T1
  • Hidden enrolment. The installment option was not shown to customers using a browser other than Safari, or Safari in private mode.
    Regulatory finding T1
  • The delay clause. Apple negotiated the $25m-per-90-days provision.
    Regulatory finding T1
  • Not verified: a single month-end statement date that strained servicing, and pressure to “approve nearly all applicants”, both from WSJ reporting relayed by 9to5Mac.P11
    Reported T2

The largest single count of un-investigated disputes came through Apple’s pipeline. The failures on disputes that did reach the bank, the credit reporting and the refund handling were Goldman’s. A fair reading debits Goldman for those, and credits it only partly for consumer-friendly terms that Apple designed. Apple said it “strongly disagrees” with the CFPB’s characterisation.R1R2P15

The consumer retreat

From 2021 to 2026 Goldman exited lending, cards, investing and personal finance. It kept the deposits.

Goldman came to describe the exits as “narrowing” its consumer focus. Its 10-K for 2025 says the Apple Card transition “will substantially complete the narrowing of such focus.”G3

Goldman’s consumer products, 2016–2028Month-level approximation
Marcus personal loansOct 2016 – Jan 2023 · servicing to SST, Dec 2023
Clarity MoneyAcquired 2018 · closed, Mar 2021
Apple CardAug 2019 – Jan 2026 · to Chase, ~early 2028
Marcus InvestFeb 2021 · to Betterment, Jun 2024
GM co-brand cardFeb 2022 · to Barclays, Aug 2025
GreenSkyAcquired Mar 2022 · sold, Mar 2024
Business line of creditStart not in the record · to Uncapped, Nov 2024
Retained
Marcus savings, US and UKFrom 2016 · retained and growing
Apple SavingsFrom Apr 2023 · retained, destination unresolved

Bars are drawn to the month where the record gives one. Marcus checking was promised for 2021, tested with employees in 2022 and never launched; with no outside customers, it is not counted as an exit. Goldman’s wealth-management sale of Personal Financial Management in 2023 is outside this page’s consumer scope.

The exits, in order

  1. February – March 2021 · Clarity Money closed

    A personal-finance app with about one million users when Goldman bought it in 2018. Closed with about one month’s notice; its features were folded into Marcus Insights.P5 Fact T2

  2. 2023 · Marcus personal loans

    New lending stopped in January 2023. About $1bn of loans was sold to Värde Partners at a $470m loss, and servicing of remaining loans moved to Systems & Services Technologies (SST) effective 11 December 2023, with original terms preserved.G8G7P6 Fact T1

  3. March 2024 · GreenSky sold

    The point-of-sale home-improvement lender, bought in 2022, was sold to a Sixth Street-led consortium; the sale closed on 15 March 2024.P7 Fact T1/T2

  4. June 2024 · Marcus Invest to Betterment

    Accounts and assets moved to Betterment on or about 29 June 2024, after a three-year product life. Customers could opt out by 20 June.A5P17 Fact T1

  5. November 2024 · business lending to Uncapped

    Business lines of credit transferred to Uncapped on 18 November 2024.G8 Fact T1

  6. August 2025 · GM card to Barclays

    Goldman had won the GM card from Capital One in 2020. It signalled its exit in November 2023, and Barclays completed the conversion by 25 August 2025.P8A7 Fact T1/T2

  7. January 2026 onward · Apple Card to JPMorgan Chase

    An agreement to move the programme, more than $20bn of balances and about 12 million users, to Chase over about 24 months, subject to regulatory approval. As of August 2026 the portfolio had not moved, and Goldman was still issuing and servicing the card.G1A4P4 Fact T1

What was kept, and why it mattered to Goldman

Consumer deposits at Goldman$bn · includes Apple Savings

Source: Goldman earnings releases.G5 At June 2026, consumer deposits were about 41% of Goldman’s $558bn of total deposits.

Investor Day 2020 target$125bn+ consumer depositsExceeded

$208bn by the end of 2025.G6G5

Investor Day 2020 target$20bn+ personal-loan and card balancesExited

Loans, GreenSky and the GM card gone by August 2025; the largest lending asset, Apple Card, agreed for transfer in January 2026.

“Our Marcus, deposit platform, has been a real strategic advantage to us in terms of overall firm-wide funding.”Denis Coleman, CFO, January 2024 · Company statementG11
“Our deposits have grown to $501 billion and now represent roughly 40% of our total funding.”David Solomon, CEO, January 2026, on all deposits · Company statementG12

Keeping the deposits was not improper. The structural point is narrower: the one consumer relationship Goldman chose to keep is the one that funds the firm.

Savings accounts are the simplest consumer product to service. Depositors kept their accounts and their terms, and Marcus continued to pay well above the national average. Goldman’s own disclosures also show the deposit business is not free money: its 2026 releases cite lower net interest margin on Marcus deposits. Analytical inferenceG5

What happened to customers

Some consequences are documented. Others are contested or still open. This page keeps them apart.

The table sets each customer population against what changed, what the record shows it meant for them, and how firmly that is established. A transfer to a new servicer or issuer is a documented fact; it is not, on its own, documented harm.

Customer populations and the strength of the evidence
PopulationWhat changedConsequence on the recordStatus
Apple Card holders, 2019–2021Disputes handled late or inadequatelyDelayed resolution, liability without investigation, credit reports on disputed sums, unexpected interestR1Documented
Regulatory finding T1
Apple Savings depositors, 2023Withdrawals delayed for weeks in what Goldman called “a limited number of cases”Delayed access to funds. $100 goodwill credits in July; controls overhauled in September 2023P2Documented
Customer report T2Company statement
Clarity Money users, about 1m at acquisitionApp closed, March 2021Loss of the product with about one month’s notice; features moved to Marcus InsightsP5Documented
Fact T2
Marcus loan borrowers, $4.5bn book at end-2022Servicing moved to SST, 11 December 2023; terms preservedNew servicer, contact details and payment processing. Notice quality is contestedG8Transfer documented
Notice: no finding
Marcus Invest customersMoved to Betterment, about 29 June 2024An adviser they had not chosen by default. Staying out meant a cash distribution that “may result in the realization of taxable gains”, or a transfer elsewhere. Later fees were not verifiedA5C3Documented
Fact T1Notice text T3
GM cardholdersConverted to Barclays by 25 August 2025A second issuer change in about three and a half years. Barclays changed the earn rate and added a seven-year points expiry; those were Barclays and GM decisionsA7P8Documented
Fact T1/T2
GreenSky borrowers and merchantsPlatform sold, March 2024No Goldman-era finding and no documented disruption from the saleNot documented
Business line-of-credit customersTransferred to Uncapped, 18 November 2024Change of counterparty; no further consequence documentedG8Not documented
Apple Card holders, 2026–2028Programme moving to Chase over about 24 monthsUsers “do not need to reapply”; Goldman services the card until the move is complete. No consequence documented yetA4Open
Apple Savings depositors, 2026–No transition agreementUncertainty rather than loss: no announced destination (see below)G12Open
Marcus personal loans and SST

Goldman transferred servicing of remaining Marcus personal loans to SST while preserving original loan terms. Available customer reports conflict regarding the quality and timing of advance notice, so CHI does not make a finding on notice quality.

Marcus’s own FAQ confirms the transfer, effective 11 December 2023, and that it “maintained original terms but changed servicer contact information and payment processing.” One borrower wrote that the change “was abruptly done without any prior notice”; another source states that borrowers received written notice at least 15 days before the transfer. Both are T3 sources, and no notice letter was located to settle the question.G8C1C2 Unresolved

Also not carried as findings: Goldman-era GM card servicing, criticised only on review sites; holds and reversed transfers reported by Marcus depositors outside the 2023 Apple Savings episode, which are T3 with unknown prevalence; and post-transfer servicing at SST, where complaints would be filed against SST rather than Goldman.

Apple Savings

The unresolved relationship. The card is leaving Goldman; the savings account has nowhere announced to go.

Apple Savings launched on 17 April 2023 at 4.15% APY with no fees or minimums, provided by Goldman Sachs Bank USA. It took $990m in four days and passed $10bn by August 2023, becoming part of the deposit franchise Goldman reports as consumer deposits.A2

Moving to ChaseApple Card. Agreement in January 2026; transition over about 24 months, “by early 2028” in reporting; subject to regulatory approval.Fact · T1/T2
Stays at GoldmanApple Savings. “There currently is no agreement to transition the savings program.” — Denis Coleman, CFO, January 2026Company statement
Not announcedFinal destination. Apple: “Further information regarding Savings will be communicated with users as the transition date approaches.”Unresolved at 25 Sep 2026
  1. May – September 2023

    Weeks after launch, customers reported multi-week delays withdrawing funds. Goldman attributed them to “processes in place designed to help protect their accounts”, issued $100 goodwill credits and overhauled its controls.P2 Customer report T2

  2. November 2023

    The WSJ reported that Apple had proposed ending the partnership within 12–15 months, covering “the entire consumer relationship, including the high-yield savings account.”P3 Reported T2

  3. January 2026

    Goldman said it would “continue to service and maintain” existing Apple Savings customers and that “Users should expect that this service will be seamless. It’ll be uninterrupted.” It described the savings balances as “just a small fraction of the deposits.”G12 Company statement

CHI leaves this unresolved. The research found no announced destination for Apple Savings, and this page does not speculate about one.

The consequence on the record is uncertainty, not loss: depositors keep their accounts, and the rate was 3.5% APY in September 2026 (medium confidence).P16 This section will be updated when the destination of Apple Savings is formally determined.

Why Goldman left

The consumer strategy became economically damaging to Goldman.

Goldman never disclosed Apple Card’s own profit and loss. Its Platform Solutions segment, which held the card partnerships and GreenSky among other platforms, is the closest filed measure.G2G3G4

Platform Solutions pre-tax result$m · as first reported

Sources: Goldman 10-K filings for 2023, 2024 and 2025. The 2025 profit is an accounting result produced by a $1,380m provision benefit. The 2025 10-K restated 2023 and 2024 without a retrieved explanation; both figures are shown. Fact T1

$470mLoss on the partial sale of Marcus loans, 2023Fact · T1G7
~$400mPre-tax hit pre-announced for Q3 2024 from unloading the GM card and a separate loan portfolioCompany statement · T2P9
$2.26bnRevenue reduction on the Apple Card book from markdowns and contract-termination obligations, more than offset by a $2.48bn reserve releaseFact · T1G1
>$1bnReported discount on about $20bn of Apple Card balances, called “highly unusual” for a card bookAnalyst interpretation · T2P10
“We tried to do too much too quickly.”
David Solomon, CEO, January 2023 · Company statementG11
“A 75 basis point to 100 basis point drag on the firm’s overall ROE.”
Goldman management on Platform Solutions in 2024, fourth-quarter 2024 earnings call, January 2025 · Company statementG12
“We’ve been clear that credit cards are not a go forward focus for Goldman Sachs.”
David Solomon, CEO, October 2025 · Company statementG12

From the firm’s perspective, withdrawal was rational. CHI’s question is narrower: what happened to customers recruited into products Goldman later decided it no longer wanted to operate?

That question does not depend on whether Goldman gained from the retreat. Across the consumer experiment as a whole, the shareholder rather than the customer bore the cost, even though the Apple Card exit itself added $0.46 to fourth-quarter 2025 earnings per share through a reserve release. The question depends on what the retreat meant for the people on the other side of each transfer, which is why the evidence above is sorted by population and by strength.

Counterevidence

The strongest evidence against a Goldman hostility thesis, and it is strong.

This section is not a disclaimer. Each item is documented, and together they are why the disposition is narrow rather than broad.

SP001 · not identified

No free feature was turned into a charge.

No Goldman consumer, wealth or asset-management product moved an entitlement from included to separately charged. Apple Card’s fee structure is unchanged from 2019 to 2026.A3

SP002 · not identified

No repricing of captive consumers.

Marcus rates tracked the Fed and were often near the top of the market; Apple Card APRs moved with prime under contract; no fee was introduced on any consumer product.

SP004 · not identified

No external cost passed through.

The only external-cost explanations Goldman gave concerned withdrawing from a business or pausing new UK customers, not raising a price.

Product economics

Favourable terms, sustained.

A fee-free card, fee-free loans and fee-free savings. Marcus paid 3.50% against a 0.37% national average in March 2026.P12

Attribution

Apple shared responsibility.

The CFPB found Apple’s own form failed to forward tens of thousands of disputes, fined Apple $25m, and recorded that Apple negotiated the launch-delay penalty.R2

Rejected allegation

NYDFS cleared the gender-bias claim.

After examining about 400,000 New York applicants, NYDFS found no fair-lending violation in March 2021: decisions were “explainable, lawful, and consistent with the Bank’s credit policy.” It did criticise customer service and a six-month appeal wait, since removed.R5

Independent satisfaction

First in its J.D. Power segment for four years.

In 2021, 2022, 2023 and 2024, including 2021, the last year of the dispute failures the CFPB found, before falling to third in 2025.A6

Continuity

Exits preserved accounts and terms.

Loan terms were preserved on transfer. Marcus Invest customers had about nine weeks’ notice and an opt-out. GM cardholders were converted, not closed. Apple Card users “do not need to reapply.”A4

Who paid

Goldman absorbed the losses.

About $6.3bn of Platform Solutions pre-tax losses in 2021–2024, a $470m loss on the Marcus loan sale and a reported discount of more than $1bn on the Apple portfolio.

Also on the record: COVID-era payment deferrals with no interest and no credit-score impact; $100 goodwill credits after the 2023 savings delays; the $19.8m of ordered redress paid in full; and relief granted on 38% of 2025 CFPB complaints.G10P2G2R6

Both things are true at once. Strong terms and a well-reviewed product coexisted with weak back-office dispute handling on a large subset of accounts. The counterevidence narrows the finding. It does not erase it.

CHI evidentiary disposition

Against CHI’s four frozen signals, Goldman’s consumer record supports one, weakly.

CHI tests four frozen signal patterns, SP001 to SP004, without redefining them. The results are research findings, not a score, and signal counts are not added up.

SP001

Unmonetized access monetization

Not supported

No customer entitlement moved from included to separately charged. The only such change anywhere in the record, research unbundling under MiFID II in 2018, was mandated by regulation, industry-wide and institutional.

SP002

Existing-customer yield extraction

Not supportedFor consumer businesses

No repricing, fee layering or benefit reduction on existing consumer relationships. The installment and refund findings produced unexpected interest, but the CFPB treated them as disclosure and processing failures, and they were refunded.

Institutional context only: 2023 CFTC orders on swap pricing marks ($15m and $30m) concern sophisticated counterparties. They are recorded as history and do not drive the consumer conclusion.R7

SP003

Legacy product deprioritization and portfolio concentration

Weakly supportedWithdrawal established · consequence uneven

The two tests of an existing product and a strategic withdrawal are met by primary documents for every exit. The third test, demonstrated customer consequence, is met unevenly across products.

SP004

External-cost pass-through

Not supported

No customer price increase was attributed to external cost. Prime-rate APR resets are contractual; accounting changes and UK ring-fencing were cited to explain withdrawal and a pause to new customers.

SP003, tested product by product
ProductTest 1 · existing productTest 2 · strategic withdrawalTest 3 · customer consequence
Marcus personal loansMetMetWeak — T3 reports, contested on notice
Apple SavingsMetPartial — Goldman still services; the partnership is endingUncertainty, not loss
Clarity MoneyMetMetModerate — product lost on about one month’s notice
GM cardMetMetModerate — two issuer changes; the rule changes were Barclays’s
Marcus InvestMetMetNot demonstrated — orderly, with an opt-out
GreenSkyMetMetNot demonstrated
Business line of creditMetMetNot demonstrated
Apple Card, credit accountMetMetNot yet demonstrated — transition under way

The research found that the Marcus loan transfer and the Apple Savings limbo would come close to full support only with primary evidence, of absent notice or of detriment to depositors, which it did not obtain. CHI therefore records SP003 as weakly supported and does not upgrade it.

Additional documented pattern · candidate only

Launch-before-ready servicing

The Goldman record documents a mechanism the four frozen signals were not built to detect, because it is not a way of making money from customers. It is recorded here as a candidate pattern. It is not an SP005, it is not part of CHI’s public methodology, and it does not change the taxonomy.

Candidate patternAlso: capacity-deficit servicingNot adopted

A company launches or scales a customer-facing financial product under commercial timing or growth pressure while knowing its servicing, dispute or fraud-control infrastructure is not ready or not sized for the volume, and customers absorb the consequences while the company remediates on its own timeline.

What would establish it

Required evidence

  • A documented warning before launch or scale-up
  • Customer consequence at scale
  • A documented commercial reason to proceed
  • Recurrence across products or time
In the Goldman record

Examples

  • Apple Card, 2019: the board warning and dispute failures T1
  • Apple Savings, 2023: $10bn in four months, then multi-week withdrawal delays T2
  • NYDFS, 2021: customer-service deficiencies T1
  • Goldman’s own words: “too much too quickly”
The case against including it

Why it may not belong in CHI

  • It describes operational failure, not monetization; it cost Goldman penalties and losses
  • Hard to tell from start-up growing pains without a pre-launch warning finding
  • Already policed by existing consumer-credit rules
  • A material share of the failure sat with a partner
  • Recurrence rests on one T1 finding and one T2 episode

Whether to adopt, reject or rename this pattern is a separate methodology decision. Nothing on this page should be read as having made it.

What remains unknown

The questions a narrow investigation would need to settle.

Apple Savings

Where the deposits go

The destination of Apple Savings balances, the number of accounts, and the rate path against peers since January 2026.

Apple Card

The move to Chase

Whether regulators have approved it, whether any accounts had moved by September 2026, and whether card numbers, statement dates or underwriting will change.

Marcus loans

The SST notice letters

What Goldman told borrowers before 11 December 2023, and how SST handled payments for transferred loans afterwards.

Run-off servicing

Service through 2028

Whether dispute handling holds while an issuer that calls cards “not a go forward focus” runs the programme, and why dispute complaints kept rising after 2024.

The CFPB order

Is the restriction still live?

Whether the 90-day compliance-plan requirement remains in force. The CFPB still lists the order as open; Goldman’s 2025 10-K dropped the heading.

Complaints

A peer-adjusted rate

Complaints per active account for Goldman against comparable issuers. Without it, the complaint trend cannot show whether Goldman is an outlier.

GM card

Goldman-era servicing

Primary servicing data for 2022–2025, and how accrued rewards were treated at the Barclays conversion.

Supervision

The Federal Reserve review

Whether the Fed’s reported 2022–2023 review of Marcus consumer-protection controls produced any action. Supervisory findings are not public.

Documents

Unreached originals

The Apple Card customer agreement, original WSJ and Bloomberg reporting, and Goldman’s own call transcripts could not be retrieved.

Conclusion

Goldman Sachs’s consumer products were, for the most part, good deals for the people who used them.

A fee-free card, fee-free loans and fee-free savings; deposit rates near the top of the market; a card that led its satisfaction rankings for four years. Goldman paid for those terms itself, and lost billions doing it.

That does not erase the record. Goldman launched Apple Card with a disputes system its board had been told was not ready, and the CFPB found that hundreds of thousands of customers bore the consequences. It then took apart nearly every consumer product it had built or acquired, moving customers to servicers and issuers they had not chosen, while keeping the deposits that had become strategically valuable to the firm. At research close, Apple Savings depositors had no announced destination for their accounts.

The strongest evidence supports criticism of execution, servicing capacity and strategic continuity, not a claim that Goldman systematically exploited retail customers. It is a basis for a narrow investigation. This page does not make a finding of hostility.

Basis for narrow CHI investigation only Standard company investigation · No numerical score assigned · Research closed 25 September 2026

Sources and method

How this page was built, and how far it can be relied on.

What was done

Twelve research streams gathered about 75,000 words of sourced notes from regulatory orders, SEC filings, earnings transcripts, product documentation, court records, the CFPB complaint database and financial journalism. They were consolidated into a master dossier with a 66-row enforcement ledger and a 118-row evidence ledger. A dedicated section assembled the strongest evidence against a Goldman thesis; this page reflects it in the counterevidence section.

Limits

Several primary hosts, including goldmansachs.com documents, the WSJ, Bloomberg, CNBC and the web archive, could not be reached, so part of the T2 evidence rests on named-outlet reporting relayed by other sites, and is labelled that way. Earnings-call quotations come from third-party transcript hosts and have not been checked against Goldman’s own transcripts. CFPB complaints are unverified submissions. The Apple Card customer agreement and the SST notice letters could not be obtained.

Conventions

Evidence is labelled by type and tier, as explained above; T3 material is never presented as fact. Goldman’s institutional businesses were researched and appear here only as context. Platform Solutions figures are given as first reported, with the restatements in Goldman’s 2025 10-K shown where they differ. Research closed on 25 September 2026.

Regulators and official records

R1

CFPB consent order, Goldman Sachs Bank USA, File No. 2024-CFPB-0011, 23 October 2024. consumerfinance.govRegulator

R2

CFPB consent order, Apple Inc., File No. 2024-CFPB-0012, 23 October 2024. consumerfinance.govRegulator

R3

Prepared remarks of CFPB Director Rohit Chopra on the Goldman Sachs and Apple enforcement press call, 23 October 2024. consumerfinance.govRegulator

R4

CFPB enforcement action pages and announcement — Goldman Sachs Bank USA (order status) and Apple Inc. (terminated 22 September 2025). Goldman · Apple · press releaseRegulator

R5

NYDFS, Apple Card investigation, press release and report, 23 March 2021. press release · reportRegulator

R6

CFPB consumer complaint database, queries for Goldman Sachs Bank USA, 2016 – September 2026, and five peer issuers for 2025. consumerfinance.gov APIOfficial database · unverified submissions

R7

CFTC orders on swap pre-trade marks, 10 April 2023 and 29 September 2023. Institutional context only. 8685-23 · 8801-23Regulator

Goldman Sachs documents

G1

Goldman press release and Form 8-K on the Apple Card transition to Chase, 7–8 January 2026. goldmansachs.com · sec.gov 8-KPrimary

G2

Form 10-K for 2024 — segment results and the “Consumer Investigation and Review” legal note. segments · legal notePrimary

G3

Form 10-K for 2025 — consumer narrowing, restated segment results, legal note. 10-K · segments · legal notePrimary

G4

Form 10-K for 2023 — segment results. sec.govPrimary

G5

Earnings releases, fourth quarter 2025 and second quarter 2026 — consumer and total deposits, Marcus net interest margin. Q4 2025 · Q2 2026Primary

G6

Investor Day presentation, 29 January 2020 (Form 8-K exhibit) — deposit and lending targets. sec.govPrimary

G7

Form 8-K exhibit, April 2024, recording the $(470)m related to the partial sale of the Marcus loans portfolio; fourth-quarter 2023 release on the sale of “substantially all” of it. 8-K exhibit · Q4 2023 releasePrimary

G8

Marcus FAQs — SST transfer, Uncapped transfer, GM card servicing ended. marcus.comPrimary

G9

Marcus Online Savings Account page, retrieved 24 September 2026. marcus.comPrimary

G10

David Solomon, written testimony to the Senate Banking Committee, May 2021 — product terms and COVID-era assistance. banking.senate.govCompany statement

G11

Earnings-call transcripts, 2023–2024 — fourth quarter 2022 (January 2023), third and fourth quarters 2023. Q4 2022 · Q3 2023 · Q4 2023Company statement · third-party transcript

G12

Earnings-call transcripts, 2025–2026 — fourth quarter 2024, third and fourth quarters 2025. Q4 2024 · Q3 2025 · Q4 2025 · Q4 2025 (alt.)Company statement · third-party transcript

Apple and other counterparties

A1

Apple Newsroom, Apple Card announcement (25 March 2019) and launch (20 August 2019). March 2019 · August 2019Primary (partner)

A2

Apple Newsroom, Apple Savings launch (April 2023) and $10bn in deposits (August 2023). April 2023 · August 2023Primary (partner)

A3

Apple Card product page, current terms as of 1 July 2026. apple.com/apple-cardPrimary (partner)

A4

Apple Card transition FAQ and JPMorgan Chase announcement, January 2026. learn.applecard.apple · jpmorganchase.comPrimary (partners)

A5

Betterment to acquire digital investing accounts from Goldman Sachs, PR Newswire, April 2024. prnewswire.comPrimary (counterparty)

A6

J.D. Power U.S. Credit Card Satisfaction Studies, 2021, 2024 and 2025. 2021 · 2024 · 2025Primary (independent)

A7

GM newsroom, GM Rewards Mastercard with Barclays, 20 May 2025. news.gm.comPrimary (counterparty)

Press and analysis (T2)

P1

“Goldman, Apple to pay CFPB $89.8M over Apple Card issues”, Banking Dive, October 2024. bankingdive.comSecondary

P2

MacRumors on Apple Savings withdrawals (June 2023, relaying WSJ), goodwill credits (July 2023) and the process overhaul (September 2023). June · July · SeptemberSecondary

P3

“Apple to end Goldman Sachs credit card partnership”, Banking Dive, November 2023, relaying the WSJ. bankingdive.comSecondary

P4

“Apple Card turns seven with big change ahead”, MacRumors, 20 August 2026. macrumors.comSecondary

P5

“Goldman winds down Clarity Money”, FinTech Futures, February 2021. fintechfutures.comSecondary

P6

Reuters report on the sale of Marcus loans to Värde Partners, via Business Standard, July 2023. business-standard.comSecondary

P7

GreenSky sale — Banking Dive, October 2023, and GreenSky’s completion announcement, 15 March 2024. bankingdive.com · businesswire.comSecondary · primary

P8

“Barclays replaces Goldman Sachs as GM credit card issuer”, Banking Dive, October 2024; GM Authority, May 2025. bankingdive.com · gmauthority.comSecondary

P9

“Goldman Sachs to post $400 million hit to third-quarter results”, CNBC via NBC New York, September 2024. nbcnewyork.comSecondary

P10

Apple Card discount and analyst estimates — 9to5Mac, February 2026; Yahoo Finance, January 2026. 9to5mac.com · finance.yahoo.comSecondary · analyst interpretation

P11

WSJ reporting on the Apple–Goldman relationship, as relayed by 9to5Mac, January 2024 and January 2026. Not verified against the original. January 2024 · January 2026Reported

P12

Marcus savings rates, Forbes Advisor, March 2026. forbes.comSecondary

P13

Marcus personal loans review, Forbes Advisor. forbes.comSecondary

P14

“Marcus moves to match Apple Savings interest rate”, Crowdfund Insider, May 2023. crowdfundinsider.comSecondary

P15

NPR on the CFPB orders and company responses, 23 October 2024. npr.orgSecondary

P16

9to5Mac Apple Card guide — Apple Savings APY listings, 2026 (medium confidence). 9to5mac.comSecondary

P17

Marcus Invest move to Betterment, Banking Dive, 2024 — opt-out deadline. bankingdive.comSecondary

Customer reports (T3)

C1

ConsumerAffairs reviews of Marcus by Goldman Sachs — including the SST transfer account of 14 December 2023. consumeraffairs.comCustomer report

C2

WalletGrower, “Marcus exit and alternatives” — states 15 days’ written notice. Not verified. walletgrower.comAggregator

C3

Hustler Money Blog, “Marcus Invest transitions to Betterment” — quotes the customer notice’s alternatives. hustlermoneyblog.comCustomer-facing blog

The complete research package, including a master dossier with a 66-row enforcement ledger, a 118-row evidence ledger and a research-gaps register, is preserved by CHI and is not reproduced here. Goldman Sachs, Marcus, Apple Card, Apple and Chase are marks of their respective owners; no logo is used, and no endorsement or affiliation is implied. This page is research, not legal or financial advice.

Reading this beside the rest of the index

Every company here is assessed against the same question. Goldman Sachs is the one whose products were generous and whose problem was execution and retreat.

Read it alongside the methodology, which explains why no number appears on this page, and the other company investigations in the Money sector.