Firstly, those who disagree with the entire concept of risk based pricing disagree necessarily with an application of that concept. Secondly the concept of one lender charging a higher price when their customer defaults with another lender has been compared to having a cartel, or price fixing structure. Thirdly, it is thought that when a customer in dire financial straights defaults with one lender, the concept of universal default, and the subsequent interest rate increases, can create a vicious cycle which can cause the customer to default everywhere. Fourthly, there is the possibility that the credit product which was shown as being in default in the first place was in default due to fraud or institutional error. If this is the case, while the customer has full legal rights to have the error corrected on his credit report, any lender who instituted the universal default rate is under no obligation to return to the normal rate. Fifthly, the increased rate is seen by some critics to be too high even reflecting the risk. Sixthly, FILO nature of the rate structure means that the customer usually must fully pay off their credit card before receiving the normal rate again.

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