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NAFCU's Andrew Morris wrote to the CFPB Tuesday in response to the bureau's review of the Credit Card Accountability Responsibility and Disclosure (CARD) Act and request for information (RFI) on the current consumer credit card market, reiterating the association's prior call for additional regulatory clarity to encourage more efficient disclosure practices, such as granting flexibility when providing required disclosures via online and mobile banking platforms.

To help credit unions develop new and innovative credit products, Morris, NAFCU’s senior counsel for research and policy, also asked that the bureau consider several amendments to the CARD Act rules, including:

• extending existing flexibility that addresses consumers’ consent to receive disclosures electronically;
• clarifying rules surrounding telephone applications for credit cards;
• updating ability-to-pay rules to better reflect the actual risk of secured credit cards; and
• granting consumers additional control over how excess payments are allocated.

“In the broadest sense, we continue to believe that new rules regarding credit cards are not warranted, unless they replace more stringent rules currently in place, given the industry’s effective self-regulation and the cumulative cost of existing compliance burdens,” added Morris.

On the current consumer credit card market, Morris broke down the role consumer credit cards play in credit union members’ daily lives but noted that “excessive regulation and significant compliance overheard” have made it challenging for credit unions to compete effectively in some areas of the market.

“Despite growing pressure from fintech competitors and the ongoing cost of cumulative regulatory burdens, credit unions continue to put their members first, providing high quality credit card products with lower than average interest rates and member-friendly fee structures,” noted Morris.

Morris recommended that the bureau ensure credit unions are given flexibility when providing the required disclosures via mobile and digital platforms. In addition, Morris reiterated NAFCU’s continuous call for more stringent data security standards for retailers similar to those imposed on financial institutions by the Gramm-Leach-Bliley Act.

NAFCU will continue to work with the bureau on its efforts to balance consumer credit card protections while ensuring a reasonable regulatory environment for credit unions.