| Comment Number: | OL-102042 |
| Received: | 11/27/2004 8:28:52 PM |
| Organization: | |
| Commenter: | David Friedman |
| State: | MA |
| Subject: | Trade Regulation Rule on Telemarketing Sales |
| Title: | Notice of Proposed Rulemaking, Request for Comment |
| CFR Citation: | 16 CFR Part 310 |
| No Attachments |
Comments:
Dear FTC, I strongly object to your proposal for altering the Federal Do No Call List. What bothers me most about your proposal is the possible abuse by companies regarding your 'removal' requirements. One of your options requires a company to provide a removal number in the message. However, it doesn't require when that number would be given. This could be abused so the message might be listed only at the end of the recording. I do NOT want to spend 5 or more minutes of my time listening to a message in order to obtain the 'removal' number. I (and I am sure millions of other telephone service subscribers) have no urge to waste minutes, hours, and eventually days of my adult life on repeated calls I never wanted to receive in the first place. Allowing abuses of this list would make you, essentially, a telephone number harvesting service. That makes you a bit like a spammer (email). Will I then find you selling lists for profit which you originally harvested in the name of my privacy? Should you go along with this proposal, I have some suggestions for modifying it to reduce the impact on my time (and my life): 1. During any prerecorded message send to a do-not-call subscriber (or anyone for that matter) require the message to always, and immediately, list removal instructions (or connect you to an operator for removal) when the user presses "0" on the touch-page or says zero aloud. This should be standardized. 2. Any calls which provide a removal telephone number should list that number in the first 5 seconds of the recording as well as during the middle and at the end of the message. 3. Ensure provisions exist to ensure that prerecorded calls do not LOCK a person's telephone until the message is completed. I have had to listen to messages which, when I hung up for a few seconds, would still be running when I picked up the phone again 10 (or more) seconds later. When you hang up on a call, it should release your phone. 4. Ensure these callers are held accountable for home (residential), cellular, and business numbers. 5. Prerecorded messages should have a maximum time limit, such as 60 seconds. Callers should not be forced to listen to anything too long, especially if they are paying minute-by-minute on a cellular service plan. 6. All incoming calls should show on caller ID the removal number. As we all know, services have cropped up which allow phony numbers to appear on caller ID units. That should be used to the consumer's advantage by making it easier to find the removal instructions for such calls. The id should also contain an updated "company" directory name including the words "solicitation" and the company's real name. Additionally, *69'ing a call from existing automated message systems often fails to connect you with a live operator. I've tried and been frustrated by that issue. This point could address that problem and ensure the removal process would run smoother. 7. Steep fines should be set. The more offenses recorded in a month, the more quickly the fines should increase per incident. This should encourage consumer reporting and discourage corporate noncompliance. It is difficult enough finding time for oneself in this busy world. Having your day interrupted by needless and often unsolicited calls at home, work, or play is simply wrong. Please make our country safer and saner by ensuring and respecting our privacy. Regards, David Friedman / Massachusetts