“Although subprime issuers send much less mail volume than larger issuers, among issuers in our dataset, these smaller issuers’ share of all mailings sent to households headed by consumers with no college education doubled from 2012 to 2014,” it noted.

The CFPB also reported mass market issuers sent about 45% of their marketing mailings to those households in 2014.

Credit unions, however, sent slightly more than 30% of their mailings in 2014 to consumers with no college education, according to the CFPB. That’s an increase compared to 2013 but is still below 2012, when the proportion was about 35%, it reported.

2. Cardholder agreements tend to be shorter and more readable.

The CFPB found cardholder agreements from mass market, subprime and large credit union issuers have gotten slightly longer since 2012. At just under 6,000 words in 2014, cardholder agreements from credit unions were about as long as those from mass market issuers, according to the report. However, at just under 10,000 words and in some cases almost 12,000 words long, cardholder agreements from subprime issuers were more than 70% longer than other agreements, it said.

Card agreements from credit unions and large issuers were readable for high school graduates, but agreements from subprime specialists required college-level reading skills, it also said. That makes those marketing mailings problematic, the CFPB claimed.

“The most complex, difficult-to-read agreements are disproportionately marketed to consumers who may be the least equipped to comprehend and navigate them,” it said.

3. Credit unions shun minimum finance charges.

In its examination of cardholder agreements, the CFPB also found that large and subprime issuers generally assess minimum finance charges. Credit unions, however, largely do not. Of those issuers that assess the charge, the range was $0.50 to $2.

“Private-label cards tended to have charges at the upper end of the range,” it reported. “General purpose cards were mostly at the other end. Subprime specialist issuers universally set the minimum finance charge at $1.”

4. Credit unions lean toward more minimal minimum payments.

Of the contractually specified practices it examined, minimum payment formulas varied most, the CFPB said.

Credit unions and subprime banks tend to use a percentage of total statement balance including finance charges; large issuers overwhelmingly use a percentage of total statement balance excluding finance changes and then add the finance charge to the minimum payment due, it explained. Unlike large issuers and most subprime banks, most credit unions didn’t specify that penalties or late fees must be paid in the minimum payment, it added.

“Among issuers that calculate the minimum payment as a share of total new balances including capitalized finance charges, credit unions universally require minimum payments of 2% of the total balances,” it said.

Subprime banks required 5% to 7% minimum payments in that sample; the one large bank that used the method charged 3% and sometimes 4% of the total balance, it reported.

Almost all issuers set floors on minimum payments; the most common was $25. Subprime issuers tended to set higher floors and credit unions generally set lower ones, the CFPB said.