Mortgage Assistance Relief Services - Proposed Rulemaking, Rule #546727-00069

Submission Number:
Ian Hirsch
Fortress Credit Services
Initiative Name:
Mortgage Assistance Relief Services - Proposed Rulemaking, Rule
These rules that are meant to help consumers will have the opposite effect. They assume that all mortgage modification companies are scams, they are not. They look at the mortgage modification process and assume that the consumers need no help from third parties, this assumption is incorrect. In Nevada, the state with the worst mortgage crisis in the country, we passed state regulations that protect consumers. These regulations should be considered prior to the acceptance of these rules. The outright ban on UPFRONT FEES WILL KILL THIS INDUSTRY, NOT REGULATE IT. If that is the intention, then make that known, do not disguise the poison as a cure. There have been people pretending to offer help to people in exchange for mortgage help, only to take the consumer's money and provide no help. IN Nevada, we changed that. We passed rules under 452F that forced companies and employees to pass rigorous background checks, submit to educational requirements, and post large bonds. NOW THE ONLY ONES THAT ARE TAKING ADVANTAGE OF CONSUMERS ARE THOSE BREAKING EXISTING LAWS. THESE NEW LAWS WILL NOT AFFECT THEM, THEY WILL AFFECT LEGAL, LEGITIMATE, LAW ABIDING COMPANIES THAT HELP CONSUMERS. Our laws allow for companies to accept funds up front through the use of TRUST ACCOUNTS that are audited by the State. Our laws also regulate attorneys the same way they regulate mortgage relief companies. OVER HALF OF THE COMPLAINTS REGARDING MORTGAGE RELIEF SCAMS INVOLVE ATTORNEYS. I submit that these rules will have the opposite effect than the stated purpose. They will leave consumers with fewer options, and they will do nothing to regulate attorneys who account for a growing part of this business. Fortress Credit is a privately funded, consumer advocate that has been helping consumers modify loans and keep their homes for over three years. I ask for the ability to address the rule making board to have my concerns heard. These rules will kill my company. Ian Hirsch