Consumers Union supports the FTC’s proposed Rule regulating for-profit companies that, in exchange for a fee, offer to work with lenders and servicers on a homeowner’s behalf to modify the terms of mortgage loans or to avoid foreclosure on those loans. With some enhancements, the proposed rules prohibiting advance fees, barring false or misleading claims, and requiring certain disclosures regarding loan modification services taken together will help to protect consumers from the deceptive and abusive practices that have been so pervasive in the mortgage assistance relief services (MARS) industry. Consumers Union also supports the Rule’s extension of liability to those who provide substantial assistance to an entity engaged in a violation of these Rules, as well as the recordkeeping, reporting and compliance requirements imposed.