16 CFR Parts 317 and 318: Mortgage Assistance Relief Services Rulemaking #542309-00026

Submission Number:
Robert Vazquez
Americas Loss Mitigation Solutions Corp
Initiative Name:
16 CFR Parts 317 and 318: Mortgage Assistance Relief Services Rulemaking
I have been involved in loss mitigation industry for a few years now, a business I have been successful in, and have helped a great number of Americans is now being slighted and questioned as whether it’s illegal or ethical to perform such services because the foolishness’s or greed of others. I myself have been contacted as apparently a business I have been providing, apparently became illegal with no warning of a change in law to me. I have unfortunately heard of companies that have taken funds from desperate homeowners and haven’t done a single bit of work. I believe these individuals need to be prosecuted. However the shot gun approach of blocking consumers from paying for services they see fit is also very unfair, and downright un-American. Some individuals have seen a need and have acted honestly to supply the demand and help consumers in a time of need when the government was slow in its attempt to help an ever increasing number of Americans from losing their homes and the after effects caused by this crisis, of so many uprooted families, vacant homes, the continuing loss of home values, and and and and the list goes on. I believe there most certainly is a continuing need for such an industry and said industry should have oversight. Regulations in the loss mitigation field should include a license, tracking & auditing, certifications etc. Homeowners need someone on their side. Someone who has their best intentions at heart. In my experience homeowners paying for services have received greater favorable results than the recommend approach of utilizing nonprofits or working directly with your lender. Unfortunately this is a long, stressful, ambiguous task and to charge a consumer a fee to help navigate them through such a task should be allowed. I will include an attachment of a requested proposal and the cost breakdown to a lender. This is not free to me as the provider of such services. In my experience to spend a small amount of funds to determine what the lender will inevitably calculate gives a homeowner/representative more negotiating room/leverage if you will to request a more feasible/favorable outcome for the homeowner. And this of course cost money. You have nonprofits that most likely receive funds from the lenders or lenders who have their investors best interest in mind, how do decision makers not see the conflict of interest in its current configuration and recommend consumers to continue this stressful cycle that often time leads to no results.So many of my clients have attempted to use nonprofits and the results they receive are minuscule at best. Offers foolish advise that has no tangible benefit to the homeowner….but bad FREE information is better than a professional helping a consumer for a fee. Navigating negotiation channels/techniques with lenders is a skilled trade. We need to regulate it, not ban it or impose laws banning the charging of such services. Please see the video at the provided link below. http://www.foreclosure-shield.com/loan-modification-video/ Congresswomen attempts loan mod for constituent and fails http://abcnews.go.com/Blotter/story?id=6702731&page=1 Now the congresswomen is not experienced in this industry, not to take anything from her however her position doesn’t entitle her (as you see in the video) to automatically receive or achieve a specific goal, utilizing loss mitigation techniques from industry professionals however can yield homeowners a greater probability of achieving said goal. A lot can be taking from that since (at least here in Florida) it seems as though the government is fishing for complaints and now broadcasting its “don’t use 3rd parties” “if you have paid contact the attorney general” A new law needs to be passed to protect homeowners from the greed of parasites, however a whole industry should not suffer for the inequitable actions of a few. I am honored to be a member of The National Loss Mitigation Association. A group of self regulating professiona