16 CFR Parts 317 and 318: Mortgage Acts and Practices Rulemaking #542308-00002

Submission Number:
542308-00002
Commenter:
david kochanski
State:
MD
Initiative Name:
16 CFR Parts 317 and 318: Mortgage Acts and Practices Rulemaking

This comment is made in an individual capacity and does not represent the views of my employer or clients. Maryland law prohibits advance fees to loan modification and forclosure rescue services. This process has been the subject of substantial abuse in Maryland aand elsewhere. Conversely, this prohibition has limited the availability of these services to many who need them most. Although the Maryland bar has undertaken a massive pro bono project it only addresses the tip of the iceberg. I would offer two suggestions: 1. Provide for contingent or sucess fees for these sevices 2. Provide for fee shifting to make these fees payable by the lenders or servicers