|Agency:||Federal Trade Commission|
|Rule:||Mortgage Assistance Relief Services - Proposed Rulemaking; Rule|
Comments:I agree that companies need to be regulated in regards to upfront modification fees. I, myself know how difficult it is to obtain a modificaiton on a mortage. Mine was denied 4 times at my current lender before I finally obtained a 12 month modification (and I work in the industry). Through out the past 3 years it seems that the companies that have chosen to do bussiness ethicaly and properly have had deal with the backlash due to the unethical bussiness practices of so many other companies. Knowing how difficult it was to get my home modified I decided to start to help close friends and family (at no charge) and after successfully completing many permanent modifications I decided to help my clients as well. Just like a mortgage, a modification is just as difficult. I also feel that one of the main reasons so many applicants for modifications have been denied is due to the consumers not understanding the exact paper work needed to send to thier servicers, how to fill it out, give up on dealing with the frustration of sitting on hold for 30 minutes to be hung up on, constant requests for new information (that may have already been sent in) etc. . . All of this work just to see if you are eligilbe for a trial modification. I do agree in some part that there needs to be regulation on upfront modification fees, but I disagree that there should be a ban on upfront modification fees. I feel the most make sense proposal would be to have two different fees for a modification. An upfront fee of minimal charge. This would be earned by doing all of the upfront work for our clients. The upfront work is exponential for numerous reasons. One it will ensure that the lenders are recieving complete modification packages, thus reducing the tedious task of tracking down page 3 of a 4 page bank statement or making sure the 4506 is executed properly. Two, this phase 1 fee would also require the consistent follow up with lenders to assure that all paperwork is in and is correct. Most of the work in obtaining a modification is the intial work. Making sure the correct income is sent in, making sure the client is even eligible for a modification, making sure the paperwork is signed everywhere, making sure the tax returns are singed if the client efiled, making sure etc. Thus making sure the homeowner is being represented by someone who put's their interest at the top of the food chain. A modification is debt settlement at the utmost highest level and unless you are in the industry and truly understand how a mortgage works how can you be expected to understand how a modificaitionw works. This is why I feel that an upfront fee for modificaiotn services is justified. Not the entire fee, just a fee fair for the services provided.