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NAFCU's Ann Kossachev asked the CFPB on Wednesday to closely evaluate the effects credit card regulations have had on the credit union industry and to conduct a cost-benefit analysis to help eliminate unnecessary regulations as it reviews the consumer credit card market.

The Credit Card Accountability Responsibility and Disclosure (CARD) Act requires periodic analysis of the credit card market, thus the bureau's review. Kossachev, NAFCU's regulatory affairs counsel, noted that credit unions have had to comply with "stunningly complicated disclosure requirements as a result of the CARD Act," which have "done little to educate consumers."

"NAFCU and its member credit unions have consistently supported providing consumers with fair and transparent financial products to suit their individual needs and goals," she wrote in the official comment letter. But, she explained, "the CARD Act's requirements, in particular the disclosure requirements, have mandated that credit unions change the way they approach the credit card market and interact with their members."

Kossachev noted that the CARD Act requirements have made it more difficult for the credit union industry to find creative solutions to better use online and mobile servicing platforms. The "ever-increasing regulation," she wrote, has caused credit unions to struggle in keeping up with compliance requirements while using technology to meet their members' needs.

Additionally, Kossachev wrote that "the CARD Act's ability to pay requirements, as applied to secured credit cards, has made it harder for credit unions to help those individuals who need access to credit the most."

She asked that the CFPB exclude secured cards from the ability to pay requirements of the CARD Act because they carry less risk than unsecured cards. "An independent ability to pay analysis for secured credit cards is just one more regulatory obstacle that has made it harder for credit unions to properly serve their members," she wrote.

She also provided the CFPB with data on credit unions' consistently low charge-offs and delinquencies related to credit card products. "NAFCU urges the CFPB to exclude credit unions from any additional credit card regulation because the existing regulations have already had a significant impact on the industry," she wrote.

Kossachev also noted how the increase in credit card data breaches is affecting the credit card market. "Despite the use of top-of-the-line security safeguards and account monitoring tools, hackers continue to find innovative techniques to invade data systems," she explained.

"NAFCU has consistently advocated for a stringent data security standard for retailers similar to the requirements imposed on financial institutions by the Gramm-Leach-Bliley Act," she added. "It is essential that the CFPB recognize the importance of and support such a legislative change because it would drastically improve the health of the credit card market."