A nice article by the PCI Guru echoing what I've been saying for years.
It's fairly clear that PCI DSS is written with a primary focus on merchants, with acquirers and particularly issuers sometimes seeming to be more of an afterthought. This is unfortunate because issuers as a class have significantly different requirements regarding what they do with cardholder data to merchants and acquirers. The same standard is applied uniformly to these different entities, potentially causing headaches for issuers who are already in the business of managing risks associated with their own portfolio.
It is possible to comply with PCI DSS while running an issuing and processing platform without any compensating control worksheets - I've done it myself. However, doing so requires discipline and focus on this objective across the organization on an ongoing basis. It also requires sufficient control of your IT infrastructure to implement and maintain solutions where PCI DSS compliance is an overriding design requirement (as it really should be in this space).
If you have already achieved the goal of PCI DSS compliance with no CCW's, congratulations! You've clearly made substantial investments which are paying off handsomely.
If you're still working towards this goal, you may want to consider streamlining the process by licensing a software platform designed from the ground up with PCI DSS compliance as a core requirement. One I can recommend, and that I'm involved with developing, is Tritium® by Episode Six.