fed_mar2005_r-1217_creditcards.pdfComment letter on the advance notice of proposed rulemaking (ANPR) on the open-end credit rules of Regulation Z.  Finds that some of the policies examined in the ANPR – such as increasing interest rates and credit limits on short notice to those in debt – are particularly destructive.  Suggests changes to the regulation that would end unreasonable fees, deceptive payment allocation, cut-off times, and universal default.