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Credit card marketers are drawing fire over how they're putting new plastic in Americans' wallets.

At least two card programs, Citibank's Ford Visa and Chemical Bank's Shell MasterCard, are soliciting new customers by automatically converting them from other cards. Both risk flouting government regulations that prohibit sending unsolicited cards through the mail.

Citibank is notifying selected holders of its "classic" and other basic credit cards that it will automatically convert them to the Ford program unless the cardholders request otherwise.

Chemical is sending new Shell MasterCards to more than half of the 7 million Shell credit card customers considered good credit risks.

Both cards offer rebates on all purchases that can be used to buy new automobiles or earn discounts on gasoline.

The newly aggressive solicitation practice comes amid an intensifying battle for share in the growing credit card business.

The success of General Motors Corp.'s MasterCard program and that of AT&T's Universal Card have drawn a spate of cobranded cards to the marketplace, many charging no annual fees and offering enhanced services like rebates. Many industry observers expect heightened competition from other new programs.

Federal laws forbid mailing plastic to customers who don't request it, unless it replaces a card that is no longer valid.

Activation of Chemical's Shell card, however, automatically cancels the original Shell card, thus technically obeying the rules.

"It's entirely proper, correct and legal .|.|. and is probably going to become one of the major processes for solicitation where an account exists and that account is replaced," said Charles Walsh, exec VP and group executive in charge of Chemical's retail card services.

And Citibank's offer seeks only tacit approval. Customers who don't say no are moved to the Ford program, and receive a Ford-branded card when their current card expires.

"We would not send any Ford plastic to anyone who did not ask to be part of the Ford program," a spokeswoman said.

But critics charge the banks are using loopholes to circumvent the spirit, if not the letter, of credit card marketing restrictions.

"It's a way of trying to sneak around the law," said Gerri Detweiler, executive director of Bankcard Holders of America, a consumer group. "We're not convinced that it meets the requirements completely for a replacement card."

Ms. Detweiler said several consumers have complained to her organization, particularly about Chemical's tactics, and Robert McKinley, president of RAM Research Corp., called the practice "borderline illegal."

But Bruce Brittain, president of Brittain Associates, another credit-card industry researcher, suggested Citibank may be obliged to goose its Ford card business because of an agreement with Ford guaranteeing a minimum number of cardholders.

Mr. Brittain also said Citibank appears to be converting inactive cardholders to the Ford program to stem attrition of its shrinking credit card base, although it still leads the industry.

Both banks denied their solicitation practices are attracting controversy.

A Chemical spokeswoman said it has received a handful of calls from customers "not understanding" the conversion process.M

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