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I think CUNA Mutual did the right thing by raising deductibles and increasing premiums on credit cards. CUNA Mutual is owned by its policy owners and we collectively were losing money on this coverage. CUNA Mutual was paying losses that were the result, in too many cases, of weak internal controls at credit unions. Credit unions now have an incentive because they are taking more of the first dollar losses to build strong internal controls for their credit card operations. That means credit unions will use neural network software like Falcon; credit unions will limit expirations dates to three years in the future; credit unions will require card activation; credit unions will carefully screen new applicants; credit unions will promptly follow up on Visa notices of compromised accounts.

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