Bair said that any major restriction to bank policies “needs to be done very carefully, given the state of the industry.”

She supports regulation to require banks to get consumers’ permission to approve transactions that overdraw their accounts and charge a fee. She also believes overdraft coverage should be treated as a loan, which would require banks to calculate and disclose the average APR to consumers. In the past, banking regulators have said that overdraft coverage is a credit product, but have stopped short of regulating it as a loan.

Banks and lenders are shoring up risks — closing a record number of credit card accounts and reducing millions of dollars in credit lines. As they clamp down, even some consumers with excellent credit and spotless payment records are seeing their credit scores reduced because of the diminished credit lines. That, in turn, can hamper consumers’ ability to get credit elsewhere.

…Bank officials say they’re aware of growing concerns about the effects credit-line reductions and account closures are having on credit scores. But as the economy worsens, they say, more consumers are struggling, so it’s only natural that institutions take steps to reduce risk before borrowers default.