In the article on the previous page, Robert McKinley of RAM Research suggests that American Express has somehow "hired" Bankcard Holders of America to conduct a campaign against bank card interest rates. He is flat wrong.

For 12 years, our message to consumers has been: Don't pay the astronomical rates most banks charge on credit cards. This message has not changed because those interest rates have not come down significantly.

In a recent report, developed by Bankcard Holders of America with assistance from independent academic research (and with no assistance from America Express), we found that many card issuers use billing practices that raise the effective cost of credit card loans, often without the cardholders' knowledge.

Consumers Stymied

Most disturbingly, we found it is impossible for consumers to get complete information about credit card costs up front.

Our report was well received by the national media and by consumers. Unfortunately, it is a message that some of the banks would rather consumers didn't hear.

Mr. McKinley's criticisms of our findings are simply wrong:

* We requested cardholder agreements from the top 25 issuers, but only four gave us the information. The others flatly refused. Cardholders are being asked to enter into contracts without being given all the details.

* Discover, Colonial National Bank, Household Bank on some accounts, and the new General Motors MasterCard all use the two-cycle balance calculation method. In other words, more than 30 million accounts are affected.

* Of the top 10 bank card issuers, which told 60% of outstandings, eight require minimum payments of less than 3% of the total balance - not 5% as Mr. McKinley states.

In addition, it would not be hard for credit card rates to reach the lowest level in years, as Mr. McKinley would characterize them, since the average has never dripped below 17%.

But for credit card rates to have dropped in line with other interest rates, the average would be under 15%. Clearly, card rates are nowhere near that level.

Mr. McKinley also contends that Bankcard Holders of America has "sold out" to American Express by participating in certain forums. We, however, considered those events an excellent opportunity to get our message out. Other than reimbursement for travel expenses, we have not accepted any compensation for those appearances.

It is important for consumers and the industry to understand that our commitment to independence does not mean that we refrain from taking sides in industry battles. To do so would be to sit out important debates affecting consumers.

Our approach is to "call 'em as we see 'em," no matter on whose side that puts us. We joined with Sears in its legal battle to become a card-issuing member of Visa. We also entered into a class action suit against Sears, regarding its violations of state prohibitions against credit card late fees.

We have joined with Visa to gather evidence for criminal prosecution of sponsors of fraudulent credit offers.

Private Company

Consider, too, where Mr. McKinley is coming from. RAM Research is a privately owned, for-profit corporation deriving half its revenue from credit industry sources.

Bankcard Holders of America is a nonprofit membership organization, almost entirely supported by consumers through dues and publication sales. Which organization's profile is more indicative of independence, objectivity, and dedication to protecting consumers' interests?

The bottom line is that consumers continue to find the information we provide helpful in making credit choices. Misplaced criticism from RAM Research (or anyone else) will not deter us from helping consumers save money and protect their rights.

Ms. Detweiler is director, Bankcard Holders of America, Herndon, Va.

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