|Received:||9/30/2009 5:21:24 PM|
|Commenter:||President Abraham Cozzi|
|Organization:||Two Bridge Debt Resolutions|
|Agency:||Federal Trade Commission|
|Rule:||16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments|
Comments:payment for debt relief services until such services have been fully performed and documented to the consumer. How the above is worded it needs to be further defined. The current practices of a % of savings based on performance with a third party fiduciary account are reasonable and customary. The attorney model will need to adjust their retainer agreements accordingly, unless they are provided an exception.