Mortgage Assistance Relief Services - Proposed Rulemaking, Rule #546727-00003

Submission Number:
David Deal
Rate Modifications, Inc.
Initiative Name:
Mortgage Assistance Relief Services - Proposed Rulemaking, Rule
Dear FTC, My company, Rate Modifications, Inc. is one of the few loan modification specialists that have been around since the beginning of the foreclosure crisis and continue to operate, even with all the roadblocks and hurdles put in our way by the State of California DRE, Department of Justice and the banks themselves. To my knowledge, we have been the only company to offer a true money back guarantee to our customers, which has been needed to ensure consumers are protected. The most frustrating thing to us in the business sector are the failings of State and Federal Governments in their so-called attempts to assist homeowners in crisis. A short list of these failings are included below. These are not meant to be angry finger shaking, but rather to prompt the FTC to stop listening to media, banks and politicians and start listening to the consumers and professionals working with them to truly understand the tragedies being suffered on the American people at the hands of the banking industry. Here is what I mean: 1. Prior to HAMP, we were successfully negotiating loan modifications for homeowners in need roughly 30 days after taking on their case. This was due to our ability to negotiate on the merits of each case on a need basis with each client. And, the banks were motivated to cooperate because modifying was smarter business than foreclosing. After HAMP, the regulations put in place made it harder for Americans to qualify (and the banks knew this) which is why they all agreed to follow the guidelines. But the guidelines don't require the banks to do anything! They offer fewer modifications for less savings now than before. 2. HAMP incentives offer banks $3,000-$4,000 to modify loans that will result in banks losing mortgage interest income at $12,000 per year on average. Can you see that this is NOT an incentive? If you truly want to motivate banks to cooperate, MATCH their losses dollar for dollar and watch the onslaught of modifications happen! The foreclosure crisis will end in 90 days. 3. Banks lie to us, to the borrowers, to the media and to the government agencies. We have several cases of clients who are approved under HAMP guidelines, but are then lied to for any number of reasons and the banks fail to issue the trial modifications.These actions go unchecked, unwatched and ignored by the agencies that claim to "govern" this industry. 4. The State DRE in CA made us use a contract that forces us to perform completed services in 90-days, but we cannot force banks to cooperate in the time period. In addition, our contacts have stated we had to refund client fees within 5 days of a request. But, banks give homeowners 30-days to accept a modification, resulting in us getting scammed out of fees for our hard earned and successful work. 5. Proposals in place now will prevent legitimate and ethical companies like us from helping clients, since we will not be allowed to charge for anything until after the 4-8 month period of time it takes to complete a modification. Ask yourselves, can you work for 8 months without getting paid? Of course not. And, no banks extend lines of credit to business like ours since the banks WANT us out of business so homeowners are left with nowhere else to go but directly to the banks where they are taken advantage of all over again. 6. I submit that NO legitimate studies have been made to investigate how many actual "scammers" have taken advantage of homeowners vs. how many legitimate homeowners have been helped by companies like mine. If you would investigate, you would find out the true scammers are the banks, not consumer advocate companies and attorneys working to help people. THE BEST MONEY YOU CAN SPEND IS TO MATCH BANK LOSSES DOLLAR FOR DOLLAR AND YOU WILL TURN AROUND THE HOUSING FREE-FALL IN 90 DAYS! I'm available for questions, statistical data and references of my claims. Call me any time. Sincerely, David Deal, CEO Rate Modifications, Inc. (866) 883-4436 ext. 120