Mortgage Assistance Relief Services - Proposed Rulemaking, Rule #546727-00047

Submission Number:
546727-00047
Commenter:
Lewis Flowers
Organization:
Westside Ministers Coalitin
State:
IL
Initiative Name:
Mortgage Assistance Relief Services - Proposed Rulemaking, Rule

FEDEAL TRADE COMMISSION 16 CFR Part 322 [RI N 3084-AB18] NOTICE OF PROPOSED RULEMAKING: MORTGAGE ASSISTANCE RELIEF SERVICES FROM: LEWIS FLOWERS WESRTSIDE MINISTERS COALITION 5308 WEST CHICAGO AVENUE, CHICAGO. ILLINOIS COMMENTS TO NOTICE OF PROPOSED RULEMAKING The Westside Ministers Coalition (WMC) located on the westside of Chicago, Illinois in the Austin community is an organization of churches, ministers, community groups, business, and social service organizations. The Austin community historically has been one of the top ten neighborhoods with a high foreclosure rate. WMC has partnered with other groups to provide foreclosure assistance and welcome the Federal Trade Commissions proposed rulemaking concerning the activities and practices of for- profit mortgage assistance relief services (MARS) providers. The coalitions comments concern aspects of the advance fee and the exemptions. Advance fee charges related to MARS, specifically section 322.5 makes it a violation to receive fees until the provider gives the achieved result and the consumer receives documentation of the achieved result. The advance fees charged for credit cards, work at home schemes, and extensions of credit are a good analogy for not charging advance fees for MARS. Whenever the full amount is paid prior to the service will not be performed or completed by the provider. The consumer is at the mercy of the provider, who maybe in another state, cannot be located, has absconded with consumers funds. And any contact information is no longer valid. The consumer loose. CONT.. ON ATTACHMENT