The rule capping credit card late fees was passed by the CFPB in March, but then a coalition of bank industry groups sued to stop it before it could become law. The law is pending appeal before a judge. Trade organizations representing large banks also sued to prevent changes to the Community Reinvestment Act, which requires banks to offer their services to low-income and historically disadvantaged communities.

Even though the credit card late fee cap hasn’t become law yet, some credit-card companies are ready to pass on costs to customers. Chase has sketched out plans to ratchet up interest rates and take a more conservative approach to underwriting credit-card loans, according to an investor presentation.