CA

This Special lets the Character playing it switch all cards currently on his or her permanent record with another front-line teammate's permanent record. Either Character participating in the exchange may have zero cards in their permanent record. This card may not be played defensively to prevent a Character from being KO'd.

Meta Rules
Meta #82 Specials that indicate that Hits on Permanent Record may be exchanged do not require either Character to actually have any hits on their record at the time. The exception being when the Special specifically mentions that two cards of a particular type may be exchanged, in which case, the Character(s) must have the appropriate type hit.