If government regulators flipped the switch on new credit card rules today, the twelve largest U.S. banks would have to pull down all of their online offers. That's the finding of a new report released by the Pew Charitable Trust in advance of Credit CARD Act regulations set to take effect in February. The Philadelphia nonprofit research group studied over 400 online credit card offers in July 2009, revealing:

• 100 percent of credit card offers studied still used terms and conditions that the Federal Reserve Bank would consider "unfair or deceptive" under the new rules
• About four in five credit cards offered online still contain "hair trigger" penalties clauses that can significantly raise interest rates after one or two late payments
• Credit unions have already started to win credit card accounts from major banks by offering lower interest rates, reduced service fees, and clearer terms

Although most banks have adjusted credit card interest rates and terms of service in advance of new restrictions, the Pew report's findings have already encouraged lawmakers to consider speeding up implementation of the Credit CARD Act.