The Credit Card Accountability, Responsibility, and Disclosure (CARD) Act is already having a palpable impact on the industry. The new rules go into effect in the February-March 2010 time frame, and the industry right now is jockeying a bit to see exactly what's going to work.

Bank of America, as TheStreet.com points out, just hiked fees a bit on some customers. We'll see some more experimentation as banks gird to lessen the revenue hit as much as possible. The laws consumer protection aims are laudable. And banks can't take them for anything other than a watershed moment.

We're likely in for a return to the past: "namely higher interest rates, the return of annual fees, and even lower credit limits for existing customers, who can most times opt out of the changes and cancel the cards." Some may seek fewer, higher value customers. TheStreet.com notes that AmEx has been "winnowing down" accounts. It has canceled 3.3 million inactive cards globally in the last two quarters. Perhaps we'll see more incentives for top borrowers.

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