|Received:||11/27/2004 6:41:27 PM|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:Despite being on the Do-Not-Call list, we still receive calls each week trying to sell us some new service. The "prior business relationship" clause of the existing system has been stretched and twisted beyond all recognition, such that companies that we have had no "business relationship" with in over 5 years are still calling. Your proposed additional loophole will effectively castrate any purpose behind the Do-Not-Call list. If you want to make an amendment of this type, then you must change the "prior business relationship" clause to explicitly define "prior" to be a window of 3 months from a prior purchase from the marketing group/client. Note the "3 month" rule is VERY SHORT. The current abuse seems to be to say, "well, we did business 15 years ago, so we can call you anyway." If you make it more than 3 months, then what's the point to the list? Now we have to keep track of every product we ever order from every company for the window you construct. If we stop buying from a company, that company's rights to call us should stop shortly thereafter. Most companies we refuse to purchase from have offended us in some way such that we want nothing to do with them again. Please, do NOT pass this proposed change. It will just make the existing loophole so much worse. At the same time, I would encourage you to put in an amendment rigidly defining the "prior" relationship to a very short fixed window of active involvement. If you consider defining "prior" to a very short period, then other amendments might be tolerable. Anything else is throwing the Do-Not-Call list in the trash.