The Credit Card Accountability, Responsibility, and Disclosure (CARD) Act established new stipulations for providing credit to consumers under 21 years of age, but the new guidelines fail to implement income standards, allowing credit card issuers to find loopholes in the new legislation, according to the New Jersey Star-Ledger.

New protections prohibit credit card issuers from extending credit to those under 21 unless they offer proof of income or have a co-signer. Credit card issuers haven’t developed a standard income-level requirement, and there are no tools in place to prove a consistent source of earnings, reports the Star-Ledger. Without the ability to accurately prove income, there may be confusion among lenders about whether a co-signer is required to help secure a credit card.

Prior to issuing a new line of credit or increasing credit limits, credit issuers are required to prove that a consumer is in a financial position that would allow him or her to repay any credit debt. To date, no procedures on proving a consumer’s ability to repay debts have been drafted, according to the Star-Ledger.

With millions of Americans facing large amounts of debt, the Credit CARD Act is intended to shield consumers from unfair lending practices, while placing additional safeguards on how credit is issued.