Removing Barriers Blog

CUNA Submits Comments to the CFPB on CARD Act of 2009
Posted May 02, 2019 by CUNA Advocacy

Earlier this week, CUNA submitted comments to the Consumer Financial Protection Bureau in response to their request for input on several aspects of the consumer credit card market, the fourth such review as required by the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009.

“As the CFPB conducts its review of the credit card market, we urge it to be cognizant that excessive regulatory requirements have the potential to divert credit unions’ resources and attention from meeting their members’ needs,” the letter reads. “The credit unions that offer credit card programs do so as a service to their members.”

Low delinquency and charge-off rates for credit unions’ credit cards remain lower than those of their bank counterparts, CUNA’s letter reads. It also notes that as member-owned financial cooperatives, credit unions have a vested interest in minimizing fees, and that credit unions face challenges that might not impact other card issuers to the same degree.

Other highlights of the letter include:

  • Credit Card Disclosures: CUNA has called for tailored regulations, including some implemented under the CARD Act, and recommends the CFPB study methods to improve and simplify disclosures as they related to both consumers and financial institutions;
  • Credit Card Data Breaches: Data breaches at retailers and merchants are a problem for credit unions, pulling staff from other services and resources taken from other areas to cover fraud losses and card reissue costs; and
  • Innovation Initiatives: CUNA reiterates its support for the CFPB’s efforts to use its authority to encourage innovation through mechanisms like the revised Trial Disclosure Program, No-Action Letter policy and Product Sandbox, if credit unions are given equal access to such programs and approved programs are limited in number and narrow in scope.