Issuance of cards or other means of access
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(a) Prohibition; proper issuanceNo person may issue to a consumer any card, code, or other means of access to such consumer’s account for the purpose of initiating an electronic fund transfer other than—
(1)
in response to a request or application therefor; or
(2)
as a renewal of, or in substitution for, an accepted card, code, or other means of access, whether issued by the initial issuer or a successor.