| Comment Number: | OL-102608 |
| Received: | 11/27/2004 11:23:24 PM |
| Organization: | |
| Commenter: | Michael McKibben |
| State: | CA |
| Subject: | Trade Regulation Rule on Telemarketing Sales |
| Title: | Notice of Proposed Rulemaking, Request for Comment |
| CFR Citation: | 16 CFR Part 310 |
| No Attachments |
Comments:
As a consumer and homeowner, I strongly object to the proposed amendment of the Telemarketing Sales Rule to create an additional call abandonment safe harbor to allow telemarketing calls that deliver a prerecorded message to consumers with whom the seller on whose behalf the calls are made has an established business relationship. I also object to the petition to to amend the TSR’s call abandonment safe harbor provision that currently requires use of "technology that ensures abandonment of no more than three (3) percent of all calls answered by a person, "measured per day per calling campaign" substituting the phrase "measured over a 30-day period.". These changes are being proposed soley to side-step or weaken the Do Not Call Registry, and will no doubt lead to widespread abuse by telemarketers. This is because telmarketers will simply claim that a prior business relationship exists where one doesn't, or will use deceptive means to establish the existence of such a relationship. These changes will put the burden and onus for enforcement back on citizens, not on telemarketers, and are an unreasonable and unfair erosion of the right to privacy of citizens. Thank you for considering my comments.