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approved or should have their approval withdrawn by the UST.
Comment on FR Doc # E8-01451
This is comment on Proposed Rule
Application Procedures and Criteria for Approval of Nonprofit Budget and Credit Counseling Agencies by United States Trustees
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