|Organization:||My Financial Path|
|Agency:||Federal Trade Commission|
|Rule:||Mortgage Assistance Relief Services - Proposed Rulemaking; Rule|
Comments:I think it is a great idea to stop up-front fees, and implement a system that holds companies to a set of standards and regulations. However, there should be some leeway if the company has to go out of pocket to prepare client documents. For example, some companies order Forensic Audits or RESPA reports through attorneys’. Some may order AVM's through Freddie Mac to present an analysis of the market to prove to the lender that it may take a loss if it forecloses. There should be some consideration given to this. A good company will do these things in the hopes of holding the lender accountable. While it is all well and good to vilify "modification" companies - It is not prudent to only look at this from one angle. Are consumers supposed to put their trust only in the lender? The lenders are the ones who were complicit in creating the current situation in the market. It seems as though lawsuits are popping up by the day regarding RESPA violations, redlining, and discrimination. If the lenders are the ones being sued, then how is the borrower suppose to rely on them to act in their best interest. Are consumers supposed to trust only in "Non-Profits"? The last time I checked Non-Profits did receive compensation from the Gov't and the lender. I would argue that a Non-Profit cannot be as effective as a good for Profit Company. A Non-Profit would not have the resources to do RESPA Reports, Forensic Audits, Market Analysis, or AVM's. These are all valuable tools if uses effectively. Also, we have seen Non-Profits treat clients like a number. The more applications they submit, the more compensation they receive. That does not bode well for verifying accuracy or if the client actually qualifies. There should be some consideration given to companies that do a real job. How are the lights, phones, computers, marketing, and payroll to be met if we only receive compensation down the road? There should be some thought to what is a fair amount that a client should pay after the file is processed and released to the client to submit to the lender. It is also fair that the client pay for any out of pocket expenses that were incured. Standards are great - This industry needs it. Please do not swing the pendulum so hard the other way that legitimate companies suffer the consequences that should be aimed at the nefarious.