the regulation which implements the Truth in

Lending Act, Bachus joined others in doubting they would be enough.

"As the Ranking Member of this Committee, I have heard numerous complaints--both from constituents and from other Members on both sides of the aisle --regarding industry practices that they view as particularly unfair, and that are in some instances enough to offend the sense of justice of the average American," Bachus said. "The level of dissatisfaction--and in the case of many of my constituents, anger--at these practices has reached a point where more than

just enhanced disclosures may be needed to address the concerns."

Lawmakers' indignation appeared particularly acute in light of the Fed's just releasing its first proposed changes to Regulation Z in 25 years and that the new regulations have not yet even made it through their comment period.

Mishkin urged, for example, that some of the Fed's changes, particularly the new requirement that cardholders be notified in advance of changes to interest rates be allowed to work before additional changes be put into law.

Credit Unions Looking Good

In general, credit union card programs came out looking very good in comparison with the rest of the industry at the hearing, with NCUA Board Chairman JoAnn Johnson drawing little of the lawmakers' ire or more pointed questions. Even with the number of credit unions which have sold their card portfolios over the last five years, Johnson reported that still roughly 50% of credit unions offer their members a credit card and, of those, 60% were under $50 million.

But she also reported that the numbers of credit unions issuing cards had declined 13% since 2002.

Because credit union interest rates are capped at 18%, credit unions have largely avoided the high rates which have drawn so much consumer anger. Their fees are generally less and their card management practices are generally considered more consumer friendly.

This appears to bring good results. Johnson reported that credit card delinquency and charge-offs at federally insured credit unions have been on the decline and that the charge-off rate for credit union card accounts stood at 2.32% while the rest of the industry's charge-off rate stood at 3.98%.

The good card practices are also seen in the relatively low numbers of complaints registered with NCUA about CU card practices. Johnson told the Subcommittee that only 306 complaints dealing with credit union card management or Regulation Z had been lodged with NCUA since 2004.

Since no credit unions were specifically the topics of the Subcommittee's hearing, few credit unions went out of their way to comment on them. No credit unions were invited to testify and CUNA did not issue a statement. NAFCU wrote the Subcommittee to reiterate many of the points Johnson did in her remarks.

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