Comment on FR Doc # E8-01451

Document ID: DOJ-EOUST-2008-0002-0004
Document Type: Public Submission
Agency: Department Of Justice
Received Date: February 21 2008, at 04:30 PM Eastern Standard Time
Date Posted: February 22 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: February 1 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: April 1 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 803ba9d6
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Here in Springfield, Missouri, the only approved credit counseling agenct for this area, Consumer Credit Counseling Services of the Ozarks (CCCSO), has a debtor's bankruptcy attorney on its board of directors. As a result, CCCSO has been stearing debtors referred to them for pre-bankruptcy counseling to this attorney's law firm exclusively or very nearly exclusively. To my mind that is improper conduct. It creates a situation where an apparent agent of the USDOJ/UST is engaging in tortous interferrence with interstate commerce. I believe section 58.17(f)(4) should include language specifically preventing a bankruptcy attorney or any attorney who's law firm handles bankruptcy cases from serving on an approved coedit counseling agency's board of directors or as an officer of any such agency. The appearence of impropiety by the USDOJ/UST is great in such circumstances. In fact I would submit it is not just the appearence, it is in fact improper. Consequently, any approved credit counseling agency that has an officer and/or director that is an attorney as discribed above should not be approved or should have their approval withdrawn by the UST.

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