"According to FICO, over 70 million people, one in three individuals in the U.S. today, find themselves in the low-limit or 'subprime' category and, as the study demonstrates, low-limit credit cards represent an effective way for many Americans to access and rebuild credit," he added.

The study, based upon a sample of 360,000 consumers, found that nearly 35% of consumers with low-limit cards improved their credit scores and more than 60% of consumers who increased their scores of 40 or more points "graduated" to higher limit cards over a two-year period. Additionally, the study found that low-limit credit cards can and do help consumers re-establish good credit.

CEAC said that, specifically, the analysis found that over a 24-month period, 35% of consumers improved their credit score. Of those that improved their credit score, 20%-24% of consumers opened prime credit cards with at least a $1,000 credit limit and 58% of consumers received prime promotional credit offers providing important opportunities to access credit.

Consumer advocates have strongly attacked the fees subprime borrowers frequently face for subprime cards.

Regulatory proposals currently open for comment from the Federal Reserve, the Office of Thrift Supervision and the NCUA would sharply rein in fees that card issuers can charge for subprime cards.

H.R. 5244, the Credit Cardholders Bill of Rights, would require all fees for subprime cards that are more than 25% of the card's total credit limit be paid by the cardholder in advance. This would effectively halt the common practice of some subprime lenders of charging fees to the card account, reducing the available credit line and generating immediate finance charges. The bill would also regulate how cards are priced.

CEAC appears to be the latest player in what has been significant push back from the banking and credit card industries against the proposed changes. The center took pains to state that an independent public policy organization, the Washington-based Political and Economic Research Council, confirmed the study's accuracy and methodology.

No one from CEAC could be contacted for an interview about the study. The organization's Web site at www.equalaccesstocredit.org provides both a physical and e-mail address for the group but no phone number. The Web site said Cuebas is a "nationally-recognized leader in the areas of institutional development, corporate responsibility, and advocacy/grassroots organizing."

According to the site, he has provided services to numerous national not-for-profit organizations including Americans for Secure Retirement, the Dominican American National Roundtable, the Hispanic Institute,

L?-deres Mexicanos, American Women in Radio and Television and the American Society of Women Accountants, among others.

But while CEAC is not yet a well-known name in the subprime credit controversy, its Web site makes clear that it has some well-known and powerful allies in its concerns about the legislation.

An Aug. 1 letter to Rep. Barney Frank (D-Mass.), chairman of the House Financial Services Committee, from the Southern Christian Leadership Conference, one of the first civil rights organizations in the U.S., said the requirement that subprime borrowers should have to pay a higher portion of card fees in advance was discriminatory.

While the SCLC called H.R. 5244 well intentioned, it nonetheless would have pernicious, unintended effects for lower income borrowers.

"Consumers with prime credit scores are not required either by statute or regulation to pay fees upfront, in advance of having a credit card issued to them," the SCLC wrote. "Therefore we believe that H.R. 5244 is discriminatory against consumers with subprime credit scores. Further, we believe this bill would cause economic harm to a great many consumers and have a negative and disproportionate impact on minorities."

Other similar letters were posted from the Intertribal Agricultural Council, an organization which claimed to represent 85% of Native American-owned land in the U.S.

In a letter to Frank, the council wrote that "low-limit credit cards are an important resource for many rural and economically depressed communities because they allow people to rehabilitate their rating."

"These cards continue to allow many to re-enter the economic mainstream and achieve a better life. Should the fee requirement provision of H.R. 5244 become law, this important resource could be eliminated. Should this occur, this would force many people to resort to dramatically less secure and affordable options when dealing with a financial emergency."

The site also contains letters from individual card holders as well, such as California resident Decca Rossignol in a July 20 letter to the Federal Reserve.

"I was involved in a major car accident a few years ago," she wrote. "My husband and I were financially wiped out due to a combination of astronomical hospital bills, rent increases, and home fuel costs increases. For a long time I had to pay cash up front for my medical expenses."

"I appreciate having our subprime credit cards because they provide me a good financial padding for us especially in the middle of the month when we are short of cash. Our credit score has improved nicely also, our credit score is now somewhere around 650. We make sure that we are doing well with our payments so our score can continue to improve. We want the chance to show that we can pay for credit and can only do this if banks are able to approve us for credit. These proposed regulations will block that avenue for people like us. It's not a good idea at all."

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