Apparently the credit card companies were the only ones caught by surprise:

Bankruptcy filings were supposed to snowball in the months before the tough new law went into effect on Oct. 17. But the avalanche of petitions, and the lines of debtors streaming out the courthouse doors caught even the credit card issuers who supported the new law by surprise.

In recent days, the five biggest bank issuers of credit cards have said that the unexpectedly large flood of filings shaved hundreds of million of dollars off their earnings in the third quarter.

But with tens of thousands of petitions still being processed and Hurricane Katrina’s impact on cardholders still being sorted out, the bankruptcy rush is likely to result in well over a billion dollars worth of losses by the end of the year.

“We thought it would cause a bubble,” James Dimon, the president of J. P. Morgan Chase, said last week. “The bubble is just bigger than we thought.”

Sallie L. Krawcheck, the chief financial officer for Citigroup, said, “It’s clearly done some short-term earnings damage to the card industry.”

How long until the first bank reports lower quarterly earnings (or even a loss) and then whines about the effects of the law they spent eight years pushing for? We’ll be watching.