How does the Lender Dispute Resolution (LDR) program violates the Federal Trade Commissions M.A.R.S Rule?

Let's take a look and review how CORE Advisory Group, LLC now CORE Advisory Group Svcs, LLC complies with the Federal Trade Commission's Mortgage Assistance Relief Services (MARS)

Rule.

Before you read this, ask yourself what is the purpose of hiring CORE Advisory Group? Just to complain to regulators about your lender? Or is it in hopes your lender will work with you to either get your home loan re-instated or modified? Well the answer is obvious and that's to cure your default with either a reinstatement or new modified loan terms so if that is the case, FTC (MARS) Rule applies and that makes it ILLEGAL to collect any fees UPFRONT. 

CORE Advisory Group (CORE), presents itself as a nationwide advocacy firm. The program offered is it's Lender Dispute Resolution program or (LDR) in which this program is broken down into two phases.

Phase One of CORE's services is filing complaints against the homeowner's lender or loan servicer with Federal or State regulatory agencies. The agencies may include filing an online complaint on behalf of the clients with the Consumer Financial Protection Bureau (CFPB) as well as filing complaints with an elected government official such as a State Senator or the Governor's office. 

The purpose of getting these complaints filed is to leverage the involvements of these regulatory agencies or government officials in order to get the clients cases heard by the banks high ranking officials at the executive level of the bank. Although this concept does have its' purposes and that's to go around the protocols of the "Loss Mitigation Department" and go straight to the top level of the banks hierarchy charts. Now the question is, how is this method going to achieve a consumer's goal, when they are trying to save their home? So let's recap this, the LDR program is designed for getting complaints open, get regulatory agencies & government officials involved. What happens after that? So no matter how clever the LDR program is designed, the fact of the matter is, the end result is still tied with some form of MORTGAGE ASSISTANCE RELIEF SERVICE. 

FTC MARS Rule Excerpt

The Rule defines "mortgage assistance relief service" as a service, plan, or program that is represented, expressly or by implication, to help homeowners prevent or postpone foreclosure or help them get other kinds of relief, like loan modifications, forbearance agreements, short sales, deeds-in-lieu of foreclosure, or extensions of time to cure defaults or reinstate loans. The Rule applies whether you work directly with consumers' lenders or servicers to get mortgage relief or you offer services to help consumers do it on their own (for example, by conducting a "forensic audit" or other review of consumers' loan documents).

Now let's take a look at Phase Two, after the completion of Phase One, the complaint campaign is successful and a point of contact from someone at the executive level of the bank is now forced to be involved. What happens at this point? Well depending on the lender in question, most will require a financial package (similar to the traditional application process for a loan modification) to be reviewed. For the most part, this is where the negotiation and waiting game begins. The result? It's either a Denial or an Approval for some form of mortgage relief. 

So as you can see, you can dress a duck however you find fitting, but at the end, it still quacks the same so it's still a duck. Same rules apply when you are assisting someone to save their home. 

NO UPFRONT FEE BAN makes it illegal to charge upfront fees until you deliver and the customer agrees to a written offer of mortgage relief from the customer's lender or servicer. That's the bottom line. 

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