The United States Court of Appeals for the First Circuit has held that, where a foreclosing mortgagee is required by HUD regulations incorporated into the mortgage, to make reasonable efforts to hold a face-to-face meeting with a borrower before foreclosure, there is no requirement that those efforts to arrange such a meeting must be made by someone with the "qualifications or authority to conduct a face-to-face meeting for the purpose of resolving mortgage delinquencies." Donahue v. Federal National Mortgage Association