Lake

ORDER GRANTING THE FTC’S MOTION FOR SUMMARY JUDGMENT

I. INTRODUCTION

Plaintiff Federal Trade Commission (“FTC”) brings this action against Defen *696 dant Denny Lake for violations of the Mortgage Assistance Relief Services (“MARS”) Rule, 12 C.F.R. § 1015.6 , and the Telemarketing Services Rule (“TSR”), 16 C.F.R. § 310.3 . 1 Before the Court is the FTC’s motion for summary judgment on both counts. For the following reasons, that motion is GRANTED.

II. BACKGROUND

Defendant Denny Lake claims to have been in the business of assisting distressed homeowners since at least February 2010. (Dkt. 126, “Statement of Plaintiffs Objections to Defendant’s Response to Plaintiffs Statement of Uncontroverted Facts” (“UF”) 1; 2.) 2 He does business as “JD United” and “the Advocacy Program,” (UF 3), and his business model has been to interview homeowners and then file complaints on them behalf with banks, public officials, and other regulatory agencies, in an attempt to get banks to negotiate mortgage modifications for them. (UF 12.) The way that Lake would retain clients was in large part by contracting with other businesses whose clients were distressed homeowners and who would refer those…