Consumer advocates and a banking-industry association are pointing to bank regulations signed into law in May as the catalyst for a host of new fees instituted on consumer credit cards.

The legislation, known as the Credit Card Accountability, Responsibility, and Disclosure Act of 2009, places new restrictions on credit card lending and eliminates some fees -- including the over-the-limit fee -- which banks have traditionally charged consumers who break through spending limits. 

The bulk of the legislation will take effect in February, but portions of it are set to come into play in the coming weeks.

But while advocates say the legislation does offer consumers some protection, it has led banks to get creative in finding new revenue streams to replace those put in jeopardy.

 “The issuers are finding new ways to secure income before the February deadline when their hands will be somewhat tied,” said Gail Cunningham, Vice President of Public Relations at the National Foundation for Credit Counseling.  Cunningham compared the legislation to a boardwalk game of “Whac-A-Mole,” where a new furry critter pops up each time you smack one back into its hole.

 “Here comes the government to knock down the mole, and doggone it if he doesn’t rear his ugly head somewhere else and find another way to bite,” she said.

Last week, American Express (AXP) sent some of its cardholders notice that the company planned to hike its annual percentage rate on cash advances, the penalty APR on cardholders who pay late, and its late payment fee.  Citigroup (C) will charge an annual fee on some cards if the holder does not use it enough. 

Nearly every card company has raised interest rates on some or all of their cards.

The American Bankers Association, a banking industry trade group, called the new fees and restrictions an “unintended consequence” of the legislation.  In fact, the ABA warned as much in April in a letter to Congress.

 “The bill contains various provisions that limit a lender’s ability to manage risk, price fees, allocate payments, and otherwise prudently conduct business,” ABA Executive Floyd Stoner said in a letter to Senate leadership. “We believe these limits will necessitate reductions in available credit given current economic conditions, while increasing the price of credit where it remains available.”

Lita Epstein, author of 25 books on personal finance, said lawmakers made a grave mistake by giving the card companies so much lead time between passage of the law and its implementation.  To have the best effect, she said, legislators should have frozen card agreements at the time the bill was signed into law.

 “By giving them an idea what restrictions were coming, they gave banks free rein to work around those restrictions -- so by the time the law is in place, the restrictions will have very little meaning,” she said.

Not all of the provisions of the law negatively affect card holders. In fact, said Bankrate.com Senior Financial Analysts Greg McBride, many should have been put in place long ago.

 “The act does outlaw some of the ‘gotcha’ practices and that is a clear win for consumers,” McBride said.

A Whitehouse spokeswoman also defended the CARD act, saying new rules of the road are needed.

"The inclination to blame the reform package for increased fees is misguided since banks are also responding to the financial crisis and losses in other parts of their businesses," said spokeswoman Jennifer Psaki.

Still, McBride said, the days of low interest rates for good customers are all but over.

 “All card holders will have to get accustomed to higher interest rates, lower credit limits and higher fees than we’ve seen in the past,” McBride said.

A spokeswoman for American Express did not directly connect the fee and rate hikes to the CARD act, saying only that the company was responding to the economic climate.

 “We have increased rates on some segments of our credit card products,” said spokeswoman Molly Faust.  “Like all companies large and small, our pricing has to be responsive to the business and economic environment and as a result we have found it necessary to increase the rates and fees on some of our products.”

Faust added that while CARD would produce some much needed reforms, the restrictions on “risk based pricing” would likely hurt some consumers.

Citigroup also declined to link the new fees to the CARD act, saying the company was responding to changing times.

"We have adjusted pricing and card terms for some customers as part of our regular account reviews," said spokesman Samuel Wang.  "This is an ongoing process to ensure we offer terms, interest rates, credit lines and products based on individual needs and risk profiles. These changes also reflect the dramatically higher cost of doing business in our industry as we work to preserve the broad availability of credit. As part of this change in terms, a small number of Citi customers may be notified of an annual fee."

Among the additional changes brought about by the CARD act are a ban on retroactive interest increase, requires consumers have at least 21 days to pay for charges and a requirement that payments be credited to the portion of the balance with the highest interest rate first.

Lenders have traditionally credited payments to the portion of the balance with the lowest interest, leaving high interest balances accruing debt.