The EOUST has published proposed rules relating to the application procedures and criteria for approval of nonprofit budget and credit counseling agencies, as well as new forms for trustee reporting. NACBA joined with Community Legal Services of Philadelphia, the Consumer Federation of America, and the National Consumer Law Center in submitting comments on the proposed credit counseling rules. In addition to the jointly-submitted comments, NACBA submitted supplemental comments on credit counseling and comments on the proposed trustee regulation. The Comments raised numerous problems with the proposed regulations and suggested changes.