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Banks in the United States have certainly had a rough year, amid a slew of high-profile failures, scrutiny from regulators and those angry torch-bearing borrowers congregating outside CEO castles. But some experts predict that domestic lenders could take even more heat, based on what has been already happening to credit card issuers overseas.In the United Kingdom, for example, “Hundreds of thousands of customers have tried to reclaim the overdraft fees they have been charged, on the grounds that they were unfair and therefore illegal,” BBC News reports. “In 2007 the UK’s banks refunded about £784m to nearly 378,000 customers.”With the CARD Act set to limit the money U.S. banks can earn from interest rates, lenders will need to make up for lost APR income using penalty fees — and that could inspire even greater anger toward card issuers. If that prediction proves true, some analysts say that U.S. banks could also find themselves in court, forced to justify their fee-based income to both consumers and Congress.

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