While you watched all your other magazines go out of business or shrink pages over the last several years, our colleagues at Consumers Union and its flagship Consumer Reports Magazine have quietly grown while successfully monetizing the net. That's something even the New York Times, Rupert Murdoch, and the Wall Street Journal (both before and after Rupertization) have failed to do.

Now, CU has announced purchase of The Consumerist, a feisty blog that rips unfair and downright sleazy business practices while offering consumer tips. From the New York Times story by Stephanie Clifford:

The blog offers consumer tips, like how to return products and how to confound a telemarketer, and covers shopper complaints, like excessive retail markups. It will become part of a new division of Consumers Union, and the current editors will remain. [...] Consumerist’s voice is younger, too: contributors write in the arch tone that is a hallmark of Gawker sites. But Consumers Union’s executive vice president, John Sateja, said that was not at odds with the more serious voice of Consumer Reports. “When Consumers Union was formed, it was a pretty snarky, aggressive organization that took on big organizations just like Consumerist is doing today; it’s just going to an audience that we basically don’t reach,” Mr. Sateja said. “It may not be language, or voice or style that Consumers Union has, in recent years, become accustomed to, but it is part of the roots of the organization.”

Attorney General Richard Blumenthal today announced that the owners of the Crystal Mall in Waterford will pay $308,736 -- mostly for refunds to thousands of consumers -- to settle allegations that they violated the state ban on gift card inactivity fees.

Now, the company's actions would be beyond the state law enforcement because it has shifted to cards issued through a national bank, deemed subject only to federal law. [...] Simon is now issuing gift cards through two national banks, MetaBank and U.S. Bank, to circumvent Connecticut's ban on dormancy fees. Because they are national banks, their cards are governed by federal law, which allows dormancy fees. Simon is charging $2.50 a month on cards 13 months and older.

The Bush Administration has become notorious for issuing rules and releases late on Fridays, hoping to miss the news cycles. The CPSC may have reached a new nadir when it issued several proposals for comment late Wednesday, December 24th, or Christmas Eve.

The proposals address various testing requirements and possible exceptions to the 2008 Consumer Product Safety Improvement Act's limits on lead in toys and children's products. (One more on lead was added today.) With the filing of a multi-association petition to the CPSC seeking lead rule delays and exceptions, along with the appearance on the scene of a grassroots effort by "small" toy companies, attacking the new act's tough limits on toxic lead seems to be at the center of industry's strategy to gut the new law's protections. Washington Post last week. CQ story today.

Today's New York Times story by Steve Lohr Health Care That Puts a Computer on the Team extols all of the purported virtues of health information technology and some of the challenges in making it work. Incredibly, the story fails to discuss its biggest challenge--privacy. The phalanx of powerful special interests and beltway bandits sweeping along well-intentioned medical and research organizations to help them push Congress to spend big on computerized health records has so far failed to ensure adequate privacy guarantees. When consent is granted virtually automatically, as it will be in these systems, privacy is at risk. Congress must go further to ensure that computerization of health records doesn't represent the death of privacy protection. For more information worldprivacyforum.org

UPDATE: More from the NYTimes story on Christmas Day. From the New York Times City Room blog: Updated, 6:27 p.m.

In an unusual move, President Bush on Wednesday reversed his decision, announced a day earlier, to pardon Isaac R. Toussie, a Brooklyn developer who pleaded guilty to fraudulently obtaining federally insured mortgages and to defrauding Suffolk County, N.Y., by selling it overpriced land.

Original post: From Newsday: Bush pardons man involved in Suffolk real estate scam.

Isaac Robert Toussie, the Brooklyn developer who served time in prison for masterminding a massive Suffolk real estate scam, was pardoned Tuesday by President George W. Bush, effectively wiping his criminal record clean. [...] Toussie pleaded guilty to charges in two separate cases. In one, he admitted in 2001 that he had made false statements to the U.S. Department of Housing and Urban Development, pleading guilty to a count of falsifying loan documents that illegally qualified about 100 home buyers for the HUD-backed mortgages.

U.S. PIRG's senior tax and budget analyst Phineas Baxandall, Ph.D., has issued a release harshly critical of the Bush administration's latest midnight regulation: New Federal Rule Requires Public Toll Roads to Mimic Profit Motives of Private Companies. Excerpt:

Last week a little-noticed action was published in the Federal Register that will make it difficult over time for states to keep their toll roads public or to operate them differently from private toll roads.[...] “This is a truly radical rule that sets a dangerous precedent,” said Baxandall.

For Immediate Release December 24, 2008
Contact: Phineas Baxandall, Ph.D. phineas[AT]pirg.org

New Federal Rule Requires Public Toll Roads to Mimic Profit Motives of Private Companies

Triggered by Government Reorganization, Ruling Sets Precedent Criticized by Congress

Last week a little-noticed action was published in the Federal Register that will make it difficult over time for states to keep their toll roads public or to operate them differently from private toll roads. The final rule, issued by the Federal Highway Administration (FHWA) on December 19th applies to state reorganization or transfer of authority for operating public toll roads to require a market valuation process that would determine what private entities would bid for operating the road under a private concession agreement. The state would moreover be required to charge that market-determined value to the public entity, regardless of whether this is best for the public.

“This is a truly radical rule that sets a dangerous precedent,” said Phineas Baxandall, a Senior Analyst for the U.S. Public Interest Research Group. “Although the rule allows agencies to determine the criteria, it nonetheless dictates that public interest considerations must take a back seat and public entities must operate to maximize market value.”

Previously, public entities could transfer operations to another public entity while giving precedence to public interest concerns. States have transferred operations without raising tolls to levels that a private investor would charge to cover their upfront payments for a toll concession. Under the new rule public-interest-based transfers would need to be justified under market-based valuation.

The House Transportation and Infrastructure Committee chair, James Oberstar and Chairman of the House Subcommittee on Highways and Transit, Peter DeFazio had issued a strongly worded letter in protest of the proposal. They questioned the judgment of the Federal Highway Administration in declaring that its rule did not constitute a regulatory action. The letter closes by saying, “this proposed rule would mark a significant departure from existing federal policy and should be considered through the upcoming reauthorization of the nation’s surface transportation programs, not through a hastily written rule in the final days of this administration.”

According to Baxandall, “If extended to other areas of government, the logic of this action dictates that no public entity can reorganize without mimicking the pricing and financing of private shareholders that would operate to maximize profit. Since private entities currently operate some water works, schools, prisons, security services and even town administrations, none of these public functions could be reorganized without comparing private bids and mandating that public entities charge what a private company would extract based on what the market will bear.”
-30-
The U.S. House letter can be viewed here. A U.S. PIRG report on private toll roads can be found here.

As part of their new credit card rules approved last week making certain unfair practices illegal, the regulators had also intended to finalize an additional -- quite weak -- rule regulating the lucrative "bounce protection" programs that banks have used to collect billions in overdraft fees. While the regulators did at the same time as they approved the credit card rules, withdraw their mediocre overdraft rule, what they ended up doing is weak also. We joined other leading groups in a news release explaining the problems with what the Fed ending up doing-- proposing two alternatives instead. The Fed's new proposal is based on two supposed alternatives. The first, an opt-out, is unacceptable; the second, an opt-in, is marginally acceptable, although the remainder of the new rule proposal simply fails to address all of the other inherent problems with overdraft loan programs. The Fed should have simply immediately required that no consumer could be enrolled automatically in one of these programs without an affirmative opt-in (e.g., without a comment period), and then proposed rules only to address the other problems with these bounce protection programs. Instead, the Fed proposed an opt-in to address some of the problems, but inanely asked for comment as to how it compared with an opt-out (duh) and ignored the myriad other problems with bounce protection in its proposal. How bad are overdraft programs? One study by our colleagues at the Center for Responsible Lending found that "the typical overdraft loan triggered by a debit card, incurring a $34 fee, is only $17." Excerpts from our joint news release explaining that:

For instance, the proposed rule does not require that consumers be provided with federal truth-in-lending disclosures about the APR of overdraft loans. A recent FDIC study noted that charging a $27 overdraft fee for a $20 debit card transaction would be the equivalent of a 3,520% APR if the overdraft is repaid in two weeks.

While the Fed proposed to prohibit most overdrafts caused solely by debit card “holds”—when a hold by a merchant exceeds the actual amount charged—it did not address check holds, when banks intentionally delay the availability of deposits, or banks’ ability to manipulate the order in which transactions are cleared in order to maximize overdrafts.

UPDATE: Larry Lessig's Newsweek piece is a pre-dot-bomb retread by Mike Weisman at Reclaim the Media.

Internet guru Larry Lessig has an interesting op-ed in Newsweek: Reboot the FCC:

We'll stifle the Skypes and YouTubes of the future if we don't demolish the regulators that oversee our digital pipelines.[...] President Obama should get Congress to shut down the FCC and similar vestigial regulators, which put stability and special interests above the public good. In their place, Congress should create something we could call the Innovation Environment Protection Agency (iEPA), charged with a simple founding mission: "minimal intervention to maximize innovation." The iEPA's core purpose would be to protect innovation from its two historical enemies—excessive government favors, and excessive private monopoly power.

Today the FTC issued a Congressionally-mandated interim study on the accuracy of credit reports.

The FTC also ordered nine large insurance companies "to produce information for a study on the use and effect of credit-based insurance scores on consumers of homeowners insurance." Our previous blog on issues related to use of credit reports to determine insurance eligibility.

Blog excerpt: Should your car insurance bill be based on how many claims, accidents and speeding tickets you have? Makes sense to us but not to the insurance industry. They want to base your rates on whether you paid your Mastercard on time last month and whether your credit score is high enough.

Two important new reports opposing state consumer health and safety law preemption:

...industry lawyers are attempting to use the doctrine of regulatory preemption to shield their clients from liability. And in a 2006 rulemaking, CPSC took their side. The rule dealt with flammability standards for mattresses, and in it, CPSC asserted that the regulation preempted state tort laws. In [the paper] CPR Member Scholars [...] dispute that argument. The Scholars examine the law of preemption in the consumer product safety context and show why the defense attorneys’ arguments fail.

UPDATE: Over at Felix Salmon's Conde Naste blog, see a long post by Adam Levitin of Credit Slips on this.

Original post: Last week, bank regulators made some unfair credit card practices illegal. Now, an empirical study by Neil Stewart, a psychologist at Warwick University, as reported on in The Economist, shows that disclosure of the minimum monthly payment encourages some consumers to pay less than they otherwise would:

Among those inclined to pay the bill in full, the presence of the minimum payment hardly made any difference. However, those who wanted to pay just part of it handed over 43% less on average when presented with a minimum payment. In the real world, this would roughly double interest charges.

The minimum monthly payment is integral to the open-end credit business model used by credit card companies. Instead of requesting full payment, or a fixed monthly payment that reduces principal significantly, card companies feature the "minimum" payment required, thus encouraging consumers to wallow in perpetual debt, since making the minimum payment each month virtually guarantees you will never pay off the card.

During the 1997-2005 Bankruptcy Wars that culminated in passage of the 2005 bankruptcy law rolling back consumer protections, a credit-card-company approved generalized provision requiring some disclosure of how long it would take to pay off a card if that minimum payment were made was included in the final law but has not yet taken effect. Better PIRG-backed notices that would provided consumers with customized disclosures of their exact "months to pay" and "total additional interest" they would pay if they continued to make only the minimum payment were defeated.

The FDIC has announced a settlement with the Atlanta-based subprime credit card firm Compucredit over charges it deceived consumers by reducing their paltry $250 limits by up to $160 or more in upfront fees. The firm will provide restitution of over $111 million to aggrieved consumers as well as pay a $2.4 million civil penalty.

From the FDIC:

The most significant claims, in terms of restitution, relate to a fee-based credit card that was marketed to consumers with low credit scores. The FDIC alleged that the solicitations failed to adequately disclose significant upfront fees and misrepresented the consumer's initial available credit. The solicitations appeared to offer credit cards with a $300 credit limit; however, consumers were immediately charged as much as $185 in inadequately disclosed fees, leaving them with as little as $115 in available credit.

Today the Federal Reserve, OTS and NCUA are releasing long-awaited rules to make certain common credit card practices illegal unfair acts. The biggest problem with this otherwise good step forward is the extraordinary delay -- until July 2010 -- before the rules will be fully enforced. Card companies are using unfair hair trigger rate increases to harm consumers now-stopping them in 2010 won't help. Clearly, in January Congress will need to enact the similar Maloney Credit Cardholder Bill of Rights to take effect immediately. Additional proposals to ban both unfair mandatory arbitration and "any time, any reason" change clauses in contracts, protect students from unfair marketing and limit unfair interest rates and high fees are also needed. We will have more when we get to a real computer with a bigger screen and better connection.

Chairman Chris Cox of the SEC has admitted that a massive failure of enforcement of existing laws helped Bernie Madoff pull off the largest and longest running Ponzi scheme in history. From the New York Times story S.E.C. Says It Missed Signals on Madoff Fraud Case by Alex Berenson and Diana Henriques: "The Securities and Exchange Commission said Tuesday night that it had missed repeated opportunities to discover what may be the largest financial fraud in history, a Ponzi scheme whose losses could run as high as $50 billion."

The story goes on to say that the SEC's failures began at least nine years ago and discusses a "romantic" relationship that became a marriage between a senior SEC compliance officer and the Madoff firm's compliance officer.

You don't have to make this stuff up. It writes itself. More from the Times:

"Besides investigating Mr. Madoff, regulators are now in the embarrassing position of examining whether they should have caught him sooner. Mr. Madoff kept several sets of books and false documents and lied to regulators when they questioned him in previous examinations of his firm, Bernard L. Madoff Investment Securities, Mr. Cox said."

The federal bank regulator known as the OCC has announced an amended settlement with Wachovia Bank over its "alleged" relationship with fraudulent payment processors who used electronic debits known as "remote checks" to debit or deduct (steal) from customer accounts. Wachovia customers will receive over $150 million in restitution (repayment of the stolen funds). The US Attorney has embraced the settlement. For more information, call (866) 680-6659 or visit RestitutionPayment.com.

As we note in a previous blog, Charles Duhigg of the New York Times broke major stories in 2007 and earlier this year on the scam. In the second, he reported that Wachovia had apparently looked the other way because of the massive profits from the fees generated by this electronic payment business, despite warnings from regulators, other banks and even its own executives:

"YIKES!!!!" wrote one Wachovia executive in 2005, warning colleagues that an account used by telemarketers had drawn 4,500 complaints in just two months. "DOUBLE YIKES!!!!" she added. "There is more, but nothing more that I want to put into a note."

It's been rumored for weeks they'd be voting on the credit card rules this month, and the agenda for the Fed's December 18th board meeting is now posted and confirms it:

Discussion Agenda:
1. Amendments to Consumer Regulations Affecting Credit Card Accounts and Overdraft Services.

The CBS Early Show did a story (watch video and read story) on the CPSC's decision to delay a Congressional ban on toxic phthalates in toys yesterday featuring U.S. PIRG Public Health Advocate Liz Hitchcock. Previous blog has details on lawsuit by allies Public Citizen and NRDC seeking to enforce the law.

We joined six other leading groups in a news release/platform and identical letters today to President-elect Obama, Speaker Pelosi and Majority Leader Reid calling for reinstatement of the long-defunct Office of Consumer Affairs headed by a White House special advisor to the President on consumer affairs (or "consumer czar"). The post was best typified by Esther Peterson, who held it under Lyndon Johnson and Jimmy Carter. We also called for urgent action on five other leading priorities: the financial meltdown, energy, health care reform, consumer legal rights and food safety.

Some recent threats to consumer rights, protections and standards of living include: the financial crisis and mortgage meltdown, high and volatile oil prices, growing concerns over the safety of imports and food, and the rising cost of health care. As a result of anti-consumer policies in these areas, the coalition has developed a six-point agenda to highlight some of the most critical issues facing the American public today.

The leaders noted that Congressional passage of comprehensive Consumer Product Safety Commission reform this summer was a positive step, suggesting that Congress may be ready to consider other important consumer reforms. Leaders of the seven groups – Consumer Federation of America, Consumers Union, National Association of Consumer Advocates, National Consumer Law Center, National Consumers League, Public Citizen, and the U.S. Public Interest Research Group, representing millions of American consumers – have united behind this agenda in response to increasing risks to consumer rights and protections.

Joan Claybrook, the dean of public interest advocates, will "step down" (release) after 27 years as Public Citizen President at the end of January to "move on to other adventures." We wish her well. Except for a stint as head of the National Highway traffic Safety Administration (NHTSA) under Jimmy Carter, Joan has been at Public Citizen in various capacities since circa 1970. She was one of the very first of the institutional (as opposed to the summer-only) "Nader's Raiders."

During my tenure, we have achieved so much for the people of this nation. Every consumer in America has benefited from our advocacy work. I am proud that Public Citizen under my leadership has played such a significant role in Congress, in government agencies and in the courts to protect the public health, safety and democracy for everyone in the U. S. In the past 27 years, we have helped pass significant laws benefiting consumers, opened access to government information, enhanced congressional ethics and campaign reform, as well as stopped some of industry’s most egregious efforts to rollback public protections.

In case you missed it, this weekend Saturday Night Live Weekend Update anchor (and Hillary Clinton impersonator) Amy Poehler, just back from having a baby herself, gave another SNL shoutout to PIRG's annual Trouble In Toyland reports--

POEHLER: "The New York Public Interest Research Group said this week that one in three popular children's toys contain hazardous chemicals such as lead, arsenic and mercury. The worst: 'I Don't Feel So Good Elmo.'"

We're proud to have had our work hit a few other popular shows over the years. "What are balloons?" was once the Final Jeopardy answer (in a special kids' tournament on the show) to the question: "PIRG finds these to be the worst choking hazard." And about 6-7 years ago, the plot of Law & Order featured a visit to NYPIRG's offices after the murder of a NYPIRG intern who'd been conducting an investigation into dangerous practices. The late actor so associated with the show, Jerry Orbach, uttered the immortal (to us, anyway) line: "NYPIRG? What's that?"

I've often written about the freecreditreport.com scam. The website is run by the credit bureau Experian. Over at Smartmoney.com, in her story FreeCreditReport.com: Not So Free -- Still, reporter Stacey Bradford points out two key astonishing facts.

FreeCreditReport.com spent a little more than $19 million on advertising during the third quarter, an increase of 28% from the same period in 2007, according to TNS Media Intelligence. A vast majority of that money -- roughly $14 million -- was spent on television ads.

The somnolent lapdog known as the Bush Administration Federal Trade Commission is responsible for the deception. Perhaps the numbers in the Bradford piece will wake them up. In weak settlements totaling a paltry $1.2 million dollars, it has continued to allow Experian to use the word "free" for its overpriced subscription service. Using the word "free" confuses consumers into thinking that they are going to the government-mandated annualcreditreport.com site where you can get an actual free credit report required by law. The web is full of other blogs that agree with me: (MSNBC Red Tape Chronicles blog, Huffington Post blog, Washington Post blog). If you are tricked into purchasing over-priced credit monitoring with the promise that it is "free", complain to the FTC and also to your own state attorney general (list here). He or she is a tough consumer cop, unlike the FTC.

Here's another thing: When the full history of the financial meltdown is written, it will describe the role of the credit bureaus. Not only did their super-duper credit scores fail to accurately warn of consumers' ability to repay, but their use of trigger lists and their incessant Internet ads for products such as lowermybills.com (also owned by, you guessed it, Experian) drove people to the mortgage companies where they got hooked on over-priced debt (previous blog). Over at his Center for Digital Democracy, Jeff Chester has written about the role of the credit bureaus in the explosive growth of behavioral advertising on the Internet.

I haven't used the dumber-than-dirt blog category often, but if Bloomberg's reporting that Treasury Secretary nominee Tim Geithner wants FDIC chief Sheila Bair out is accurate, that idea is dumber than dirt. Bair has done yeo-woman work closing failed banks at little cost to the insurance fund while also pushing creative ways to keep consumers in their homes through foreclosure assistance plans that protect neighborhoods and taxpayers. In his keynote speech today at the Consumer Federation of America Financial Services Conference, House Financial Services Committee chairman Barney Frank (D-MA) signaled very strong support for Bair, a Republican and Bush appointee. Chairman Frank said that the other bailout chiefs are apparently like little boys in a treehouse with a sign saying "no girls." He also said that her portfolio of responsibilities should be expanded. Barney also expressed disappointment that President-Elect Obama has not stepped up his own messaging on the economy and the problems with the bailout. Let's hope Senate Banking Chairman Chris Dodd (D-CT) agrees with Frank that Bair is a breath of fresh air as a creative, independent DC bank regulator and should stay. Both Dodd and Frank have repeatedly expressed disappointment that the bailout panjandrums (Geithner, Bernanke and Paulson) have not only failed to use any of the billions of dollars they were given to directly protect homeowners, but have also expressed seeming indifference to the way that the banks feeding at the bailout trough have failed to make loans but instead used taxpayer funds for acquisitions, dividends and lavish executive compensation. From Bloomberg:

Dec. 4 (Bloomberg) -- Timothy Geithner, President-elect Barack Obama’s choice for U.S. Treasury Secretary, is seeking to push Federal Deposit Insurance Corp. Chairman Sheila Bair out of office. Geithner, president of the Federal Reserve Bank of New York, has argued Bair isn’t a team player and is too focused on protecting her agency rather than the financial system as a whole, according to two congressional officials and a person familiar with his thinking. Bair has battled with Geithner and fellow regulators over aid to Citigroup Inc. and other emergency actions, making her enemies in the Bush administration.

Our allies at NRDC and Public Citizen have filed a lawsuit (here is the shorter news release) challenging a recent letter opinion from the CPSC general counsel to plastics and toy industry lawyers telling them that they can continue to sell toys laden with toxic phthalates until they run out, even though the clear opinion of Congressional leaders and bill sponsors is that the new law prohibits the manufacture, sale or importation of toys containing more than trace amounts of the toxic chemicals after February 10, 2009. Congressional conferees on the bill have sent at least three letters to the CPSC challenging its view (previous blog). Since that blog, chief House sponsor Bobby Rush (D-IL) has added his own letter to the letters to the CPSC already mentioned -- one from conferee Senator Barbara Boxer (D-CA) and another jointly from phthalate amendment sponsor Sen. Dianne Feinstein, joined by two House conferees, Reps. Henry Waxman (D-CA) and Jan Schakowsky (D-IL), and by bill co-sponsor Rep. Diane DeGette (D-CO).

In reporter Joe Nocera's New York Times blog last week: The Worst Is Yet To Come: Anonymous Banker Weighs In On The Coming Credit Card Debacle.

The non-partisan Congressional Government Accountability Office (GAO) has released Troubled Asset Relief Program: Additional Actions Needed to Better Ensure Integrity, Accountability, and Transparency. From GAO's summary:

Treasury has yet to address a number of critical issues, including determining how it will ensure that CPP is achieving its intended goals and monitoring compliance with limitations on executive compensation and dividend payments. Moreover, further actions are needed to formalize transition planning efforts and establish an effective management structure and an essential system of internal control.

"The GAO's discouraging report makes clear that the Treasury Department's implementation of the TARP is insufficiently transparent and is not accountable to American taxpayers," House Speaker Nancy Pelosi (D-Calif.) said, referring to the acronym for the bailout program, officially known as the Troubled Asset Relief Program.

Our colleagues at the Michigan-based Ecology Center have released their latest list and searchable database of toxic toys at their site healthytoys.org. They use an XRF gun, which is an excellent (but expensive) screening device for lead and other toxic heavy metals that's being rolled out by a number of manufacturers. CPSC inspectors and state officials are also using them. Excerpt from the Ecology Center release:

The Ecology Center determined that 1/3 of the toys they tested had "high" or "medium" levels of chemicals of concern this year. Lead was found in 20 percent of the toys tested, including 54 products (3.5 percent) that exceeded the 600 parts per million (ppm) state legal limit set last year and 164 (10.7 percent) above the American Academy of Pediatrics recommended ceiling of 40 ppm. Children's jewelry remains the most contaminated product category. "There is simply no place for toxic chemicals in toys," said Mike Shriberg, Ph.D., Ecology Center's Policy Director.

A massive new FDIC study confirms that most (77%) large banks are offering "automated" (you don't sign up, it's a "feature") overdraft or bounce protection programs and accruing billions of dollars in revenue. The programs have been heavily criticized by nearly every major consumer and civil rights group, including PIRG. In the 110th Congress, remedial overdraft fee legislation offered by Rep. Carolyn Maloney (D-NY) languished in committee due to fierce opposition from the banks.

Here are a few selections from the executive summary, confirming what we already know (that these these programs are unfair, tricky, and make lots of money for the banks at the expense of younger, less-well-off consumers):

Aggregate data from over 1,000 banks:

You get the idea. There's a lot more in the study and its accompanying exhibits.

Consumeraffairs.com website is reporting that Chase is imposing a $10/month "service fee" on some credit card customers with very low balance transfer or other promotional interest rates. That's equivalent to a $120/year annual fee. Chase is also raising their minimum payments.