16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments #543670-00072

Submission Number:
543670-00072
Commenter:
President Abraham Cozzi
Organization:
Two Bridge Debt Resolutions
State:
NY
Initiative Name:
16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments
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.