A new report from the Filene Research Institution has outlined how credit unions can position their credit card programs to take the greatest advantage of the CARD Act of 2009.

"The implications for credit unions are exciting," wrote George Hofheimer, chief research officer for Filene. "Large-scale issuers may retain the competitive advantages of sophisticated automated underwriting and efficient back-office operations. The CARD Act now limits many fees and penalties that are unfriendly to consumers, so large issuers will likely develop new ones to reenergize their profits," he wrote in the executive summary to the report The Credit C.A.R.D. Act: Opportunities and Challenges for Credit Unions.

Adam Levitin, associate professor of law at Georgetown University and author of the report, argued that the strategic place for credit unions is to focus is simplicity and transparency while doubling down on collaborative credit card efforts to improve efficiencies. Doing so will allow credit unions to pick off the current and future malcontents fleeing bank behavior.