Consumer Credit Regulation: 8.7.1 Deceptive Marketing
Some credit card lenders have engaged in questionable marketing practices when soliciting consumers. “Bait and switch” tactics had been common before the Credit CARD Act. For example, some credit card lenders marketed “no annual fee” credit cards, then imposed an annual fee six months later using a change-in-terms notice.492 They heavily advertised low “fixed” rates, but subsequently raised rates through change-in-terms notices and penalty pricing.493