San Francisco-based Consumer Action said last week that rising credit card rates and fees are impacting consumers with a poor credit history who cannot transfer debt to cards with better terms. The consumer group also criticized bankruptcy reform and punitive interest rates. CA found that penalty rates ranged from 14.50% charged by Arkansas National Bank to 29.99% for consumers with cards issued by Associates National Bank, Direct Merchants Bank and Household Bank. The CA survey already appears to be out-of-date. Due to the adjustments in general interest rates since the first of this year, credit card interest rates have fallen sharply. According to CardData ([www.carddata.com]), the average interest rate charged for standard credit cards by the top ten U.S. issuers for February was 17.00% compared to 18.76% for December. Platinum card rates by the top ten issuers has fallen to 13.06%. Gold card average rates, currently 18.11%, are the highest due to the pricing employed by Capital One and Providian.