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The CFPB is beginning to collect information that will be included in its biennial report on the state of the credit card market. NAFCU is seeking credit unions' comments on how their practices with regard to credit cards might have changed in the past two years.

The bureau is required to review the state of the credit card market by the Credit Card Accountability Responsibility and Disclosure Act (CARD Act). NAFCU, in a Regulatory Alert sent to member credit unions Wednesday, notes that the bureau's request for information (RFI) seeks commentary including, but not limited to, a review of:

• the terms of credit card agreements and the practices of credit card issuers;
• the effectiveness of disclosures of terms, fees, and other expenses of credit card plans;
• the adequacy of protections against unfair or deceptive acts or practices relating to credit card plans; and
• the extent to which implementation of the CARD Act has affected the costs and availability of credit, the safety and soundness of credit card issuers, risk-based pricing, and credit card innovation.

In addition to any practices that might have changed, NAFCU would also like to know if:

• credit unions' current credit card disclosures are effective;
• innovation of credit card products has changed;
• the cost or availability of credit cards has changed;
• credit unions have experienced difficulties in determining a member's ability to pay for a share-secured credit card; and
• credit unions have any additional feedback on the function or health of the consumer credit card market.

Credit unions can submit comments to NAFCU through the Regulatory Alert until April 16; comments are due to the bureau May 1.