Guidelines and Declaration of Principles for Corporate Member Companies

• A member company that markets and sells loan modification programs
• A member company that provides negotiations and customer service
• A "Full Service" member company that markets, sells, negotiates and performs customer service for loan modification clients

Halo Mac Individual Membership (Memberships for Individual Professionals)
Halo Mac Vendor Membership (Product & Support service providers, software companies, payment processing companies, etc)

Requirements of Membership

Basic Requirements

1. Members and Candidates must adhere to federal and state laws as they affect the Clients privacy over personal and confidential information.
2. Members and Candidates must maintain a "brick and mortar" location.
3. Members and Candidates shall be open no less than 40 hours per week between Monday and Friday.
4. Members and Candidates shall offer and apply loan modification services to any individual that needs the service in a non-discriminatory manner.
5. Members and Candidates shall provide loan modification services to clients that are qualified based on a review from information provided by Client.
6. Members and Candidates shall conduct an initial review and analysis of clients debts and obligations.
7. Members and Candidates shall fully and completely describe the methodology of loan modification including all the advantages and disadvantages in a way that’s easily understandable to clients so that client can make an informed decision on whether or not the loan modification process is right for them.
8. Members and Candidates must fully evaluate each client to determine if the loan modification process, and result, will be an affordable and viable option for client.
9. All client agreements must contain a three (3) day rescission clause allowing clients to rescind their agreement without financial penalty or obligation.
10. Members and Candidates will have formal and continuous training for their staff in areas including, but not limited to: sales, negotiations, customer service, and compliance.
11. Members agree to adhere to the policies set forth in the Member Enforcement & Termination Policy. This policy is posted on the website and given to new members upon registration.

Website

1. Physical address of office including street address, city, state, and zip code
2. Main telephone number
3. Email contact address
4. A “Privacy Policy” Link that discusses privacy concerns
5. A “Terms of Site” link that discuses terms of website
6. Program Disclaimer
7. Members shall publish on all websites owned by the Member the appropriate Halo Mac logo with a link to Halo Mac’s website for Client authentication of Seal and ensure that link remains active. (see Halo Mac logo licensing agreement)

Misrepresentation

Marketing

Fees & Accounting

1. Members and Candidates must only charge fees for loan modification services that are reasonable and customary. Fees will be separately itemized, fully disclosed, explained, and agreed to by Client. Fee refund policy shall be clearly explained and stated in contract with Client.
2. To receive payment in advance for services rendered (advance fees), Members and Candidates must have client sign an Advance Fee Agreement that clearly states what services will be performed and how much client must pay for those services.
3. Halo Mac encourages loan modification companies to perform services at discounted fees and/or for free to clients that are unable to afford or pay for loan modification services.
4. Members and Candidates shall not co-mingle with client funds and use a 3rd party trust account to handle clients funds when necessary.
5. Members and Candidates must follow a policy that ensures Client files be kept intact, stored, and preserved for a minimum of 3 years.

References to Halo Mac and Membership Review

1. When referring to Halo Mac, Halo Mac Membership, or designation, Members and Candidates must not misrepresent or exaggerate the meanings or implications of membership in Halo Mac, or holding any designation by Halo Mac.
2. Members may be reviewed for compliance at the discretion of Halo Mac.
3. Membership status shall be reviewed annually by Halo Mac. Halo Mac reserves the right to amend these “Standards for Corporate Member Companies” as Halo Mac deems necessary. Membership with Halo Mac is a privilege and can be cancelled or revoked by Halo Mac at any time.

Guidelines and Declaration of Principles for Invidivual Members

Requirements of Membership

Basic Requirements

1. Members and Candidates must adhere to federal and state laws as they affect the Clients privacy over personal and confidential information.
2. Members and Candidates shall offer and apply loan modification services to any individual that needs the service in a non-discriminatory manner.
3. Members and Candidates shall provide loan modification services to clients that are qualified based on a review from information provided by Client.
4. Members and Candidates shall conduct an initial review and analysis of clients debts and obligations.
5. Members and Candidates shall fully and completely describe the methodology of loan modification including all the advantages and disadvantages in a way that’s easily understandable to clients so that client can make an informed decision on whether or not the loan modification process is right for them.
6. Members and Candidates must fully evaluate each client to determine if the loan modification process, and result, will be an affordable and viable option for client.
7. Members and Candidates will pursue continuous training and continue their education in residential finance.
8. Members agree to adhere to the policies set forth in the Member Enforcement & Termination Policy. This policy is posted on the website and given to new members upon registration.

Misrepresentation

Marketing

Fees

References to Halo Mac, Halo Mac Membership and Membership Reviews

1. When referring to Halo Mac or Halo Mac Membership, Members and Candidates must not misrepresent or exaggerate the meanings or implications of membership in Halo Mac.
2. Members may be reviewed for compliance at the discretion of Halo Mac.
3. Membership status shall be reviewed annually by Halo Mac. Halo Mac reserves the right to amend these “Standards for Corporate Member Companies” as Halo Mac deems necessary. Membership with Halo Mac is a privilege and can be cancelled or revoked by Halo Mac at any time.

Halo Mac New Member Enforcement and Termination Policy

New Member Policy

Trailing/Outstanding Documents


1. New members will hold a "Provisional" membership during the time in which any trailing documents have not been received by Halo Mac (articles of incorporation, licenses, certifications etc) Upon receipt of trailing doc’s, full membership will be granted.
2. New companies may be secret shopped by Halo Mac, or a 3rd party vendor contracted by Halo Mac, at any time during the course of membership.
3. This New Member Policy does not supersede Halo Mac’s right to review all membership applications and reject any application at its sole and absolute discretion.

Violations of Membership


• Lack of response on client validation letter request.
• Falsely reporting client numbers on Client Validation.
• Failure to Pay Membership Dues.
• Non-compliance of Halo Mac Logo standards.
• Lack of Response to a Consumer Complaint Received by Halo Mac.

Any of the following constitutes a gross violation:


• A significant number or frequently repeated minor violations
• Conduct that on its face rises to the level of malice, fraud, intentional bad faith or unconscionable or serious intentional misconduct.
• Evidence of an overall failure to abide by Halo Mac standards as a whole or engaging in activities that are significantly inconsistent with Halo Mac standards.
• Failure to abide by core standards specifically including the following:
1. Failure to completely and accurately disclose all fees in loan modification agreement with client.
2. Engaging in any sales or marketing that is unfair or deceptive
3. Failure to conduct a review of a homeowner’s budget to determine the homeowner can afford the loan modification.
4. Misuse of a consumer’s confidential information.
5. Directly holding or controlling consumer funds.

Disciplinary Actions