Following the housing bubble burst in 2008, the federal government, and many state governments, undertook dramatic legislative reform to prevent “predatory lending” which included outrageous rates and hidden fees. In California, the legislature determined that a mortgage modification fee could be considered predatory and, as a result, restricted lenders, attorneys, licensees, real estate agents, and Loan Servicing companies from charging such fees. (CA SB Senate Bill 94, which took effect in October 2009)