|Received:||11/29/2004 8:24:03 AM|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:On item one (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 am strongly opposed. This could easily turn into a vehicle for mass delivery of unwanted calls. Joint marketing plans could be developed that side step the intended restrictiond and which would allow companies to become for-profit conduits for unwanted campaigns. Please DO NOT reject this change and continue to protect consumers from such practices. On item two (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"), I think that that is a almost a rational change. As an engineer, I recognize the possibility that various causes outside the control of the marketing organization may make it difficult for them to ensure compliance when measured across a very narrow time span. This expansion of the compliance window would not (in my opinion) create any real opportunity for abuse ONLY if the it is tied to each campaign. Therefore, wording of the form "measured over a 30-day period per campaign" would be both fair, practical and provided continued protection for consumers.