March 25, 2010 Federal Trade Commission Title: Notice of Proposed Rulemaking and Request for Comments Subject Category: Mortgage Assistance Relief Services - Proposed Rulemaking, Rule No. R911003 My name is Thomas Kim and I am the President of U.S.HomeSupport. Over the last year we helped many home borrowers pursue the Making Home Affordable program, however it has been very difficult for not just us, but for the millions of homeowners who have inquired within. Records show only 4% have completed the program out of the 3-4 million projected home owners. That is only 120,000 160,000 homeowners who were granted a permanent loan modification. The program has simply not worked and I anticipate the changes on June 1st will increase these dismal numbers. It has been very frustrating for profit firms and non-profit firms just to get the straight answer from the lender in terms of a homeowners qualification for a loan modification. U.S. HomeSupport is a For-Profit company and we have been legitimately performing loan modification services for over one year now and we only collect fees when the borrowers are accepted to the trial program. I am sure there are many legitimate companies offering the same time of service, regardless if they are a real estate company or a law firm. At the same time, the loan modification industry has been tarnished by many unscrupulous companies who have taken advantage of homeowners and those companies must be shut down which I applaud by state and federal agencies. I do need to question companies such as U.S.HomeSupport who currently has an A+ Rating with the Better Business Bureau. What happens to borrowers who refuse to pay after services are rendered? I have never seen a publication or article about the ones that have received modifications, however refused to pay the firm that represented them. We have no recourse for action, except for small claims court. I believe borrowers should be held accountable for services they sign through a loan modification company. One solution to the proposed rulemaking is to receive a federal government grant for legitimate companies such as U.S.HomeSupport, where no fees would be charged to the borrower. I can assure the FTC that U.S.HomeSupport would do it the correct way, not like other organizations such as NACA who received millions of dollars from the federal government, crammed borrowers in convention centers across the nation, over promised and under delivered mortgage relief to thousands of borrowers. Another issue of course, are the servicers themselves. Bank of America (BAC Home Loans) being one of them. They repeatedly loose documents and mandate documents constantly be sent to them over and over again for whatever reason. They are lost, never received, outdated because they waited to long to review the file. BAC advises us that the submission needs to start over again which has wasted more time on a borrowers ability to save their home which eventually results in foreclosure. In addition they hire incompetent call center representatives in the United States and India who have no knowledge of the program and criticize the very folks who do know the program. What recourse can be taken on the lenders? U.S.HomeSupport 1442 E. Lincoln Avenue, Ste 206 Orange, CA 92865 Sincerely, Thomas Kim President P.S. I have attached several documents that support my findings in this article. If you wish to contact me, our office address is below. Thank you for letting me submit my comments.