In issuing the final rule, the FTC stated that, "under the final rule, service providers continue to be covered, and therefore, along with the record owner
, bear responsibility for the proper disposal of consumer information that they maintain or otherwise possess.
An example of common mistakes made by the lienor is to misdescribe the property or the true record owner
of the property.
BCCI is not the record owner
of any shares of CCAH; the shares of CCAH are registered in the names of various individuals and corporate entities.
GMAC Mortgage Company of Pennsylvania will act as record owner
of the mortgages and as servicing agent for Fannie Mac.
It becomes harder to have an immediate positive impact upon the premises without some level of cooperation from the record owner
in terms of producing records and rent rolls, collection efforts, condition of the premises and other issues affecting the building.