Comment on CFPB-2013-0016

Arbitration vs Litigation, when do pre-default issues get discussed? 1. Most people don't know that credit card debt will not be restructured until it is first declared a default. If I had known this secret rule, I would have never borrowed the money in the first place. 2. Litigation Delayed, is super profitable for credit card companies. Citibank is rate jacking my closed account to well over 29% for the past 30 months, raising my closed account by over 5,000 dollars. All this while I CareGive for an elderly parent who would not have survived without my assistance & who I cannot leave home alone long enough to hold down even a part time job. 3. Credit Card companies & Debt Collection agencies regularly ABUSE the sanctity of actually legally serving the debtor by claiming to subserve someone who lives in the same residence. Debt Collectors routinely file false service affidavits and say they did a proper subservice. I have been falsely subserved TWICE. Servicing companies purposely pick the most generic height and weight when they make up a false sub-service, judges accept it all the time. 4. Judges who allow cases to go forward that involve false service suffocate a debtors negotiating position with the credit card company. This would explain why Citibank is comfortable waiting 2 and 1/2 years before attempting ligtigation, they know at any time they can hire a robo server to falsely serve me, meanwhile they are raking in a 30% monthly interest rate. 5. Judges limit the scope of their involvement to whether or not a default has occurred, placing no relevance on if the default was voluntary or involuntary. This is insane. 6. Judges regularly convert unsecured debt to secured debt, an accepted yet bizarre practice. If an unsecured debt can become secured, was it ever really unsecured? 7. Debtors use funds that could have gone to a lawyer to instead keep making credit card payments, yet are viewed as deadbeats by the court when they show up without a lawyer.