Credit Card News: Regulator Wants Your Views

According to yesterday’s Washington Post: “the Federal Reserve wants to know what consumers think” about its latest proposals for future credit card regulation, which it published earlier this month. Regulations covered credit card rates, fees, and terms. The Fed wants your views? Yeah, right.

Navigating the Fed’s website is never easy, but finding a way to comment on the new proposals defeated this writer completely. True, it’s not too hard to find a press release that says: “Comments on the proposal must be submitted within 30 days after publication in the Federal Register, which is expected shortly.” And that press release has a link to a dense, 43-page Federal Register PDF extract on the proposed credit card rules. But, personally, finding a way to actually to comment proved impossible.

Credit Card Consumer Consultation in Action

So it was back to the Post to learn:

If you want to comment on the proposals, send an e-mail to regs.comments@federalreserve.gov. Include “Docket No. R-1384″ in the subject line. You can also comment by fax to 202-452-3819; remember to include the docket number. Comments must be received on or before April 14.

Very consumer-friendly. A cynic might almost wonder if the Fed really wants to hear from those who actually use credit cards, or whether it would rather just receive comments from the credit card companies’ lawyers.

Credit Card Companies Fed’s Priority?

You can find such cynics among the New York Times’s editorial staff. The paper carried a leader Monday that said: “The Fed has a long history of putting the credit card industry first and consumers far behind, and a draft of the rules released this month is disturbingly weak.”

And the Times isn’t alone in thinking that the Fed’s ties to credit card companies are too close. Earlier this month, Rep. Barney Frank (D-MA), who is chairman of the House Committee on Financial Services, issued a statement in which he said:

I do not support housing the Consumer Financial Protection Agency in the Federal Reserve. I continue to vigorously support the House-passed bill that establishes an independent agency with strong rule-writing authority and enforcement powers to implement consumer protections… My main objection to housing this critical function in the Federal Reserve has been the central bank’s historical failure to implement consumer protection as a central part of its mission and role.

Have Your Say on Credit Cards

If you want to have your say on credit card rates, terms, fees, and so on, the Consumers Union can help. Its creditcardreform.org site has a form that allows you easily to submit your views to the Fed.

Credit Card News: Regulator Wants Your Views

According to yesterday’s Washington Post: “the Federal Reserve wants to know what consumers think” about its latest proposals for future credit card regulation, which it published earlier this month. These cover credit card rates, fees, terms, etc. The Fed wants your views? Yeah, right.

Navigating the Fed’s web site is never easy, but finding a way to comment on the new proposals defeated this writer completely. True, it’s not too hard to find a press release that says: “Comments on the proposal must be submitted within 30 days after publication in the Federal Register, which is expected shortly.” And that press release has a link to a dense, 43-page Federal Register PDF extract on the proposed credit card rules. But, personally, finding a way actually to comment proved impossible.

Credit Card Consumer Consultation in Action

So it was back to the Post to learn:

If you want to comment on the proposals, send an e-mail to regs.comments@federalreserve.gov. Include “Docket No. R-1384″ in the subject line. You can also comment by fax to 202-452-3819; remember to include the docket number. Comments must be received on or before April 14.

Very consumer-friendly. A cynic might almost wonder if the Fed really wants to hear from those who actually use credit cards, or whether it would rather just receive comments from the credit card companies’ lawyers.

Credit Card Companies Fed’s Priority?

Such cynics can be found among the New York Times’s editorial staff. The paper carried a leader Monday that said: “The Fed has a long history of putting the credit card industry first and consumers far behind, and a draft of the rules released this month is disturbingly weak.”

And the Times isn’t alone in thinking that the Fed’s ties to credit card companies are too close. Earlier this month, Rep. Barney Frank (D-MA), who is chairman of the House Committee on Financial Services, issued a statement in which he said:

I do not support housing the Consumer Financial Protection Agency in the Federal Reserve. I continue to vigorously support the House-passed bill that establishes an independent agency with strong rule-writing authority and enforcement powers to implement consumer protections… My main objection to housing this critical function in the Federal Reserve has been the central bank’s historical failure to implement consumer protection as a central part of its mission and role.

Have Your Say on Credit Cards

If you want to have your say on credit card rates, terms, fees, and so on, the Consumers Union can help. Its creditcardreform.org site has a form that allows you easily to submit your views to the Fed.

Credit Card Use to Change?

There are whispers circulating around credit card companies about fundamental changes ahead. A few are forecasting the effective death of the industry, but most predict something less radical.

The majority expect to see a new era in which banks take time to discover what consumers need–and value–in their credit card use, and respond with offers that both cost and deliver more. At the moment, card holders tend to see products as a commodity, and–in all but exceptional circumstances–make buying decisions based exclusively on cost–credit card rates and fees.

The hope is that, by offering (and charging for) new, valuable services, card issuers will move from being “fear-based” enterprises to “value-based” ones. But it’s hard to see how that can work out unless the companies drastically reduce the number of credit cards they issue, and cancel many of the accounts held by less profitable customers.

Credit Card Regulation Behind Move?

The industry would have you believe that recent and proposed credit card regulation is behind the possible changes. And they’d be right, at least in part. Earlier this week, the New York Times reported that JPMorgan alone could “lose income from legislation limiting credit card and overdraft charges, perhaps as much as $1.25 billion.” However, most card issuers are more exposed to unrepayable credit card debt than to regulatory issues, and double-digit rates of “charge offs” (when banks write off debts as uncollectible) have been routine for many card companies for some time.

But obviously it’s easier to rail against the government than come to terms with one’s own past unwise lending policies. And there’s a better chance of lobbyists heading off further regulation if the card companies focus on on the financial impact of the recent Credit CARD Act.

Credit Card Debt Main Driver?

When it comes to higher credit card rates and fees–and to any future structural changes in the industry–it seems likely that the main driver will be poor lending decisions in the past. And it’s not clear that things are getting much better today.

Last Friday, the Federal Reserve published its latest data on consumer debt and, on first reading, it contained good news. Outstanding revolving credit (which mostly comprises credit card debt) stood at $864.4 billion in January. Of course, that’s a huge amount, but it’s $70.7 billion less than it was in the first quarter of 2009, and a whopping $93.7 billion down on its highest recent level in the last quarter of 2008.

So surely that means that Americans have responded responsibly to the credit crunch, and have been paying down their credit card debt. Well, maybe not. Yesterday, the Associated Press ran a story that contained a sobering figure. It said: “In 2009, banks wrote off a record $83.27 billion in credit card debt.”

Credit Cards in the Future

It’s hard to see how that sort of charge-off rate can be sustained. And, if the economy picks up, it won’t have to be. But credit card companies are unlikely to want to put themselves in the same position ever again, so a restructuring of the industry is very much in the cards.

It may be that in the future many fewer Americans will have credit cards, and that those who do will pay more, and receive new and valuable benefits. But, as long as other financial products are created to fill the gaps, that may not be such a bad thing.

Credit Card Regulation Proposals Watered Down?

Last week, this column quoted a statement made by House Financial Services Committee Chairman, Barney Frank (D-MA). Speaking about the proposed Consumer Financial Protection Agency (CFPA), he said: “My main objection to housing this critical function in the Federal Reserve has been the central bank’s historical failure to implement consumer protection as a central part of its mission and role.”

But, just days later, Senator Chris Dodd (D-CT), who’s steering CFPA-enabling legislation through the Senate, implied that he was ready to cave into Republican pressure, and override Rep. Frank’s concerns by housing the new regulator in the Fed. He told CNBC:

Where it [the CFPA] is housed, where it rents space is important, but more importantly is what authority, what power does it have, how much independence. And again, I think we’re getting a good chance for some strong bipartisan cooperation on that.

Credit Card Rates–a Story

Yesterday, the Philadelphia Inquirer ran a feature under the headline: “Why Consumers Need an Independent CFPA.” And it told the story of an academic at the University of Pennsylvania who used to have a credit card with a $15,000 limit and an eight percent rate. When the professor decided to carry a $10,000 balance over for a couple of months, the issuer doubled the rate. Of course, he protested, at which point the bank pointed to a clause in his agreement that allowed it to increase credit card rates “at any time for any reason.”

The Inquirer pointed out that this was common practice, but that it took a year for a regulator to “advise” credit card companies that it was inappropriate, and another four years for legislators actually to ban it. And the feature, written by Jeff Gelles, one of the paper’s business columnists, concluded:

Consumers need a cop on the beat: a truly independent agency that can write and enforce rules to protect families today and nip new abuses in the bud – before they sow the seeds of tomorrow’s financial catastrophes.

Credit Card Regulation and the Fed

It’s certainly true that the Fed hasn’t in the past covered itself in glory when it has attempted credit card regulation. Even its latest proposals, announced last week, have met with a decidedly mixed response.

For example, Gail Hillebrand, director of the Consumers Union’s Defend Your Dollars campaign, commented:

The Fed’s proposal will help to bring down penalty fees and stop some of the most unreasonable new fees. But it doesn’t go far enough because it does nothing to rein in penalty interest charges and lets banks wait another year before reviewing the sky high interest rates imposed on many consumers over the past year.

And the Associated Press quotes Nick Bourke, manager of the Safe Credit Cards Project at The Pew Charitable Trusts, as saying: “The Fed left a lot of leeway for issuers to determine on their own what to do.”

Credit Card Regulation to Tighten?

Yesterday, the Federal Reserve unveiled fresh proposals that it hopes will provide new protections for credit card users. These are intended to prohibit many unreasonable fees, and they will also require banks to “reconsider” recent hikes in credit card rates. In a statement, Federal Reserve Governor, Elizabeth A. Duke said:

This proposal addresses two key costs of using a credit card–fees and interest rates. The rule would prevent credit card issuers from charging large penalty fees for small missteps by consumers and would require issuers to reevaluate rate increases imposed since the beginning of last year.

Credit Card Terms

The Fed’s ideas (they’re a long way from being implemented) for regulating fees fall into three broad categories:

1. Every penalty fee would be capped to the dollar amount of the transgression that triggered it. So, for example, the fee for the late receipt of a $20 minimum payment could not exceed $20.
2. All inactivity fees to be banned.
3. One violation of credit card terms = one fee. So no more multiple fees for a single transgression.

Credit Card Rates

When it comes to credit card rates, the Fed has two proposals:

1. Credit card companies must advise customers why a rate has increased.
2. “Require issuers that have increased rates since January 1, 2009 to evaluate whether the reasons for the increase have changed and, if appropriate, to reduce the rate.”

Nobody Loves the Fed

The Fed’s suggestions seem to have been met by near-universal derision, which can in itself be a considerable recommendation for any regulatory announcement. In covering the story, the New York Times and the Washington Post reported negative reactions from both bankers and consumer groups.

Kenneth J. Clayton, for instance, a senior vice president of the American Bankers Association, told the Times: “The issues addressed by this proposal are complicated and, despite good intentions, may mean higher prices for credit card customers, and some may see their accounts closed.”

Meanwhile, Nick Bourke, manager of the Safe Credit Cards Project at the Pew Charitable Trusts, complained to the Post: “They didn’t fully seize the opportunity.”

Credit Card Regulation Remains Challenging

So far, trying to make credit card use more fair has been like trying to produce a ballet for cats. As soon as the main players learn what’s required of them, they set about finding ways to do their own thing. Certainly, credit card companies have been exceptionally creative in getting around each new wave of regulation.

And some believe that–owing to its close connections to the banking industry–the Fed is the wrong body to regulate card issuers. So when it was recently suggested that the proposed new Consumer Financial Protection Agency should be housed within the Fed, many were unhappy.

For example, House Financial Services Committee Chairman, Barney Frank (D-MA), said in an email sent to this reporter yesterday: “My main objection to housing this critical function in the Federal Reserve has been the central bank’s historical failure to implement consumer protection as a central part of its mission and role.”

Credit Cards Vital

One thing’s for sure. Living without credit cards in modern America is difficult. And a fair way to make them affordable needs to be found.

Credit Card Companies Asking for Cancellations

With their recent imposition of higher credit card rates and new annual fees–not to mention inactivity fees–it feels as if some card issuers are actively encouraging their customers to cancel accounts. Certainly, large numbers of consumers resent being asked to pay for something that was previously offered free and are asking themselves whether they need so many cards.

But before cutting up any plastic, you should think twice. Because closing a card account may well adversely affect your credit reports.

Credit Score Calculations

Your FICO credit score–the one that most lenders use–is calculated using five criteria, and the importance of each is represented by the percentage weighting shown in the following list:

1. Your payment history (35 percent)–mostly affected by late payments
2. How much you owe (30 percent)–most importantly, the difference between the amount you’re currently borrowing and your available credit
3. Length of your credit history (15 percent)–generally speaking, the longer your credit history, the higher your score
4. New credit (10 percent)–your score is likely to suffer if your credit report shows multiple recent applications for new credit
5. Other factors (10 percent)–a whole list of these, including whether your mix of credit types (mortgage, auto loan, credit cards) is healthy

Credit Scores and the Cancelling of Credit Cards

The reason your FICO score might suffer if you cancel a credit card is associated with the second factor in that list. The relationship between your available credit and the amount you actually owe is called your “utilization ratio.” When you reduce your available credit by closing an account (and so losing that card’s limit), you’re likely to increase that ratio and potentially harm your score.

Of course, if your use of credit is already low, then the effect is likely to be minimal. But if you transfer balances, the impact could be more damaging.

One expert gave yesterday’s Washington Post an example. Suppose someone closed card accounts in a way that increased their utilization ratio from seven percent to 85 percent. If that person’s credit score had previously been in the 800s, it could end up in the low 700s, or even in the high 600s, solely as a result of the ratio rise.

Credit Scores Matter

The U.S. General Services Administration’s website explains the impact that a poor credit score can have on all borrowers. This particular scenario shows the effect on a couple who are buying their first home:

Let’s say they want a thirty-year mortgage loan and their FICO credit scores are 720. They could qualify for a mortgage with a low 5.5 percent interest rate. But if their scores are 580, they probably would pay 8.5 percent or more–that’s at least 3 full percentage points more in interest. On a $100,000 mortgage loan, that 3 point difference will cost them $2,400 dollars a year, adding up to $72,000 dollars more over the loan’s 30-year lifetime.

Of course, interest rates (and property prices) have changed since that example was written. But the point remains valid. And that is–credit reports matter.

Credit CARD Act

When, last year, legislators wanted a sharp acronym for the law that would create this week’s credit card regulations they came up with “Credit CARD”, which stands for “Credit Card Accountability, Responsibility, and Disclosure.” And consumers are about to find out just what the last of those, Disclosure, means.

Because, from now on, every monthly statement must contain two additional pieces of information. First, they must tell cardholders how long it will take them to pay their current balances down to zero, assuming they continuously make only minimum payments. And secondly, the statements must reveal how much they would have to pay each month if they wanted to pay off their balances over the following three years.

Credit Card Companies Unhappy

Few credit card companies are likely to welcome this innovation. The website of BB&T, one bank that has for years been candid with its customers about these matters, explains why:

Credit card companies usually calculate the monthly minimum payment due as a percentage of your outstanding balance. The percentage is usually more than the interest rate they are charging on your balance, but low enough to make the minimum payment amount seem attractive. After all, they make money by charging interest on what you owe.

Credit Card Debt That Keeps on Taking

And the site goes on to give an example of someone with a $5,000 balance taking virtually 25 years to pay off their credit card debt making only minimum monthly payments. That’s with absolutely no new transactions, penalties, or other fees.

That wasn’t a real-life example, because the bank deliberately chose simple figures to illustrate its point. But those figures are sensible, if not conservative (the credit card rate, for example is 12 percent) and the scenario is all too real.

And Then There Were Two

Most of the provisions of the new Credit CARD Act came into force Monday. And that was the day that Discover Financial Services chose to unveil its new website, which is designed to promote responsible credit card use among its customers.

This website, according to a company press release, offers a number of informative articles and videos that could assist cardholders in managing their money better. And it also provides some online tools that genuinely could be helpful. The press release describes these:

• The Spend Analyzer: this tool offers cardmembers a clear, visual way to track and compare their card spending so they can make informed spending choices
• The Paydown Planner: this option helps cardmembers create a simple plan to pay down their balances
• The Purchase Planner: this tool helps cardmembers understand how a large purchase can affect their account

Good Credit Card News

Not everyone welcomes this week’s new credit card regulations. Some believe that government regulation is rarely effective and often brings unintended consequences.

But it is hard to see how the greater openness and transparency ushered in by the Credit CARD Act’s Disclosure provisions can be anything other than widely beneficial. And, anyway, Credit CAR Act would have been a terrible acronym.

Credit Card Regulation Has Limits

Elizabeth Warren, the Harvard law professor who chairs the Congressional Oversight Panel, was a guest on HBO’s Real Time with Bill Maher show on Friday. And she drew an analogy that graphically explains the limitations of new credit card regulations that come into force today.

She said that relying on laws to control credit card companies was like building a fence on open prairie. The new act erected 10 fence posts (one for each of its key provisions, depending how you define “key”), but any half-decent lawyer–and card issuers employ armies of them–could get around them.

Ms Warren advocated the creation of a super regulator. To extend her simile, the regulator would be like cowboys, permanently stationed at each end of the fence, who would turn back stampeding steers.

Credit Card Terms Already Changed

Issuers have already taken advantage of the nine months between the signing of the act and its implementation to change many credit card terms in ways that disadvantage their customers.

For example, the law prevents companies from hiking credit card rates except in certain very specific circumstances. So the issuers simply switched many cards from fixed-rate deals to adjustable-rate deals, allowing them legally to increase the interest charged when wider rates increase.

More Loopholes

Yesterday’s Washington Post carried a piece under the headline, “Beware of the Loopholes in the New Credit Card Law” that detailed other potential abuses. These include pressurizing customers to opt into costly overlimit fee programs, the re-balancing of fee structures so that those not covered by the new law become more expensive, and the imposition of exorbitantly high penalty interest rates, which are still not capped by the federal government.

Chi Chi Wu, who is a staff attorney at the National Consumer Law Center, told the Post:

We’ve always known credit card companies are very, very clever in getting more profit out of consumers. And they are going to be even more clever in finding ways to make more money even with these new rules.

Credit Card Rates Up

Meanwhile, ABC News reported–also yesterday–that the average rate offered to those making new credit card applications was 13.6 percent last week, up from 10.7 percent during the same period last year.

At the same time, the number of credit card offers for accounts with annual fees jumped from 25 percent in the last quarter of 2008 to 43 percent during the same period in 2009. And issuers have been imposing other new sorts of fees, including those for paper statements and account inactivity.

Fees levied on balance transfer credit cards have also increased widely. For instance, JPMorgan Chase has hiked its balance transfer fee from three percent to five percent.

Credit Card Companies Feeling the Pinch

Sunday’s Financial Times covered the story from the industry’s point of view. It said:

US credit card issuers are facing a $12bn revenue shortfall this year from price limitations imposed by new rules that take effect on Monday, according to an analysis by law firm Morrison Foerster…. Over five years, the overall hit to the industry could exceed $50bn, analysts and industry groups said.

Credit Card Regulation Only a Week Away

After what has felt like an eternity, the Credit CARD Act of 2009 finally comes fully into force (except for certain provisions that affect gift cards) on February 22. And few will breathe a bigger sigh of relief than parents whose children have student credit cards.

That’s because credit card companies long ago began to direct their slick marketing techniques toward those on college campuses. Of course, they saw all youngsters as potential new customers who could remain loyal credit card users for decades. But students were particularly valuable because college graduates are more likely than most to be both affluent and, consequently, good credit risks.

Credit Card Companies on Campus

Back at the end of 2008, the New York Times investigated some of the methods that card issuers used to target students. Perhaps the most surprising fact uncovered in the subsequent report was that hundreds of colleges across the country had signed agreements with card companies. In fact, Bank of America alone had 700 such deals in place at that time.

Many contracts contained confidentiality clauses, so their details remain unknown. But the Times found that one university received a dollar for every successful credit card application (as long as the account wasn’t closed within 90 days), three dollars for each card with an annual fee, and half-a-percent of all the retail purchases made using cards that fell within the deal.

The Times quoted a student newspaper editorial from a different university: “…it doesn’t take a giant leap for someone to ask why the university should encourage responsible spending when it receives a cut of every purchase.”

New Protections

As of next week, the new credit card regulations sweep away these cozy deals, along with the ubiquitous tents, and stands that credit card companies used to erect on campuses. Gone too willbe the T-shirts, blankets, sandwich vouchers, and other promotional goodies that card issuers used to exchange for completed credit card applications.

Because the Credit CARD Act not only outlaws these, but also makes it illegal to issue a card to anyone under 21-years old who does not have independent means unless their parent, guardian, or another adult co-signs the agreement. Even then, the adult will have to give written permission before the credit limit on the card can be raised.

Giving Leverage to Parents

This provides parents with some much-needed leverage when protecting their offspring from unmanageable credit card debt. And if those parents believe that their child is unable to take responsibility for a credit card at all, then it allows them to insist that the student use only cash, or a combination of cash and a debit card.

Of course, there are real advantages to having cards for those who can manage them responsibly. Part of one’s credit score is based on the length of one’s credit history. So, for example, college graduates who haven’t had a card could pay more for, say, a car loan when they’re 23 or 24 years old. They might even be declined completely.

Credit Cards and the Young

It’s generally a mistake to see credit cards as instruments of the devil and credit card companies as invariably evil. In the modern world, it can be tough to get by without a card, and many students learn very successfully how to manage their finances during their college years.

But few will mourn the passing of the years that saw credit card issuers regarding campuses in much the same way that the cowboys wearing black hats used to view small, wild west towns. And most parents welcome the opportunity to participate more actively, and (if they have any sense) more constructively in their children’s financial lives.

Credit Card Regulation Imminent

Most of the provisions of the Credit Card Accountability, Responsibility, and Disclosure Act of 2009 (the Credit CARD Act) are due to come into force four weeks today, on February 22. But opinion is divided on just how effective the new credit card regulation will prove.

Credit Card Companies’ Shares Down

Last Friday, ABC News reported that shares in two credit card companies tumbled when Scott Valentin, an analyst at FBR Capital Markets, predicted that the credit card market would shrink as a result of three factors, one of which was the new law. American Express shares fell 8.5 percent, while Capital One fared even worse with a 12.1 percent drop.

The ABC News report said:

During a conference call Thursday, American Express Chief Financial Officer Dan Henry noted that the regulations could lower AmEx’s yields on credit cards, which were at 9.7 percent in the latest quarter. Margins at Capital One are also expected to decline to about 15.5 percent, down from 16 percent, Valentin noted.

Credit Card Trends Uncertain

But not everyone sees credit card trends as being so clear cut. Also last week, the New York Times carried a piece questioning whether the new law would have teeth as sharp as Mr. Valentin thinks.

It pointed out that the current regulator, the Office of the Comptroller of the Currency (OCC), is on record as opposing some of the key provisions of the Credit CARD Act, and questioned just how enthusiastically it would enforce laws with which its senior officials disagree. And it quoted Travis B. Plunkett, legislative director for the Consumer Federation of America, thus: “The O.C.C. to the end fought the rules and tried to get huge exceptions, carrying water again for the large banks they were regulating. Now they have to enforce this law that they disagreed with.”

New Law Already Leaky

Back in May, when the President signed the new act, Congresswoman Carolyn B. Maloney (D-NY), wrote about the law, which she had co-authored: “This legislation, Public Law 111-24, will end the most abusive practices of the credit card industry and level the playing field between cardholders and credit card companies.”

But her optimism already seems misplaced. Since May, card issuers have found highly creative–and entirely legal–ways to generate new streams of income that are likely, at least in part, to make up for the revenues that the new law cut off.

For example, Alliance Data Systems recently announced that it would charge its customers a dollar a month for the privilege of receiving statements by mail. And, of course, many companies used the grace period between the act’s signing, and its implementation to hike rates, introduce fees, and generally change credit card terms and conditions in ways that were disadvantageous to consumers.

Nature of the Beast

Some question whether it is possible to frame laws that can effectively contain those who issue credit cards. Last July, Shailesh Mehta, who used to be chairman and CEO of Providian Financial, recorded a remarkably candid interview for PBS’s Frontline program. In it, he observed:

[Some industry people will say,] “As long as I’m in compliance with what the government says, it’s none of anybody’s business to tell me what to do.” That’s the kind of mind-set with which … some people work. … “You make the stupid laws, I’ll comply, and I’ll make money. … Tell me the rules, and then I’ll outsmart you all.” …

A New Regulator?

Whether or not it will ultimately turn out to be possible to rein in credit card companies, many in government plan to keep trying. Their latest move is to propose the creation of a Consumer Financial Protection Agency, which, they hope, can close off legislative loopholes even as issuers discover or create them. Chuck Bell, who is programs director for the Consumers Union, is an advocate for the new agency. He was quoted earlier this month as saying:

Not surprisingly, the credit card companies have been resisting and stonewalling fair consumer protections every step of the way. Many consumers are reeling from the industry’s last-minute efforts to impose drastic rate increases on balances, add new fees and penalties, and jack up minimum payment requirements, before the law went into effect. Creating a national Consumer Financial Protection Agency is the next critical step to stamp out new tricks from the credit card industry, and help millions of Americans get out of the cycle of never-ending debt.