BEFORE THE FEDERAL TRADE COMMISSION
IN THE MATTER OF:
TELEMARKETING REVIEW - COMMENT FTC FILE NO. P994414
ORGANIZATION: National Association of Consumer Agency Administrators
TELEPHONE: (202) 347-7395
The National Association of Consumer Agency Administrators ("NACAA") appreciates the opportunity to comment on the Telemarketing Sales Rule ("Telemarketing Rule") and its importance to consumers. NACAA supports public agencies responsible for ensuring a fair and informed marketplace and representing the interests of consumers. NACAA is a nonprofit association representing approximately 165 consumer agencies at all levels of government in the United States and other countries.
NACAA member agencies across the country receive consumer complaints and inquiries about a vast array of issues and concerns, including telemarketing fraud. NACAA is supported by, and works with, various state and federal regulatory and enforcement agencies who assist in creating a fair but competitive marketplace for consumers and industries. It is from this perspective that NACAA offers the following comments for consideration by the Commission in reviewing the Telemarketing Rule.
The Telemarketing Rule is an important tool for law enforcement in the protection of consumers against fraudulent telemarketers. In particular, the opportunity of State Attorneys General to file actions in federal court is an important first step in turning the tide against fraudulent telemarketers. It has also been vital that the Federal Trade Commission has actually filed many actions against companies under the Telemarketing Sales Rule to act as a deterrent against companies that are considering engaging in such conduct. NACAA urges the Commission to continue to actively enforce the Telemarketing Rule and to increase the effectiveness of the Telemarketing Rule in protecting consumers.
NACAA supports the Comments filed by the National Association of Attorneys General. NACAA urges the Federal Trade Commission to strengthen the Telemarketing Rule to provide additional protections for consumers against fraudulent telemarketing activities. The need for additional protections are essential now more than ever because more and more illegal telemarketing companies are locating outside the boundaries of the United States. Enforcement authorities need a stronger Telemarketing Rule to reach these companies.
We specifically urge the Federal Trade Commission to:
NACAA wants to thank the Commission for the opportunity to submit Comments on the Telemarketing Sales Rule. Should you have any questions regarding our Comments, please feel free to contact us.