CUNA and NAFCU are concerned about the CARD Act's proposed fee structure and the requirement to reevaluate a card user's interest rates every six months.

Those are the key points the trade associations expressed in separate letters to the Federal Reserve. The rules, which will implement the law passed last year to overhaul credit card laws, would take effect on Aug. 22.

CUNA and NAFCU take issue with the proposed ban on levying multiple penalty fees on an individual transaction. Under the proposal, a credit union could only charge one fee per transaction. For example, it could charge a late fee or a returned payment fee but not both.

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