Mortgage Assistance Relief Services - Proposed Rulemaking, Rule #546727-00002

Submission Number:
546727-00002
Commenter:
David Baker, Esq.
Organization:
Law Office
State:
MA
Initiative Name:
Mortgage Assistance Relief Services - Proposed Rulemaking, Rule

The rule needs to be clarified so that it does not apply to properly licensed attorneys engaged in the practice of law (as opposed to operating a "mortgage modification" business). A mortgage modification is a legally binding contract with serious consequences. They are written in legalese that a lay person likely would not fully understand. In that situation, a consumer would be ill-advised to enter into the modification without having consulted an attorney. While the rule, as written, has obvious consumer protection benefits, including attorneys among those who must comply with the rule is inappropriate because it will discourage attorneys from accepting a client who needs a modification. Thank you for your consideration of my view.