|Received:||12/10/2004 12:52:25 PM|
|Commenter:||Douglas A Ward|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:With regard to the VMBC petition, the cost of pre-recorded message dialing is much lower than using live callers. Given the current loose definition of EXISTING BUSINESS RELATIONSHIP, I believe that the change of rules will cause a huge increase in unsolicited calls. Under your current definition of EXISTING BUSINESS RELATIONSHIP, there is nothing to stop every corporation with which I perform a credit card transaction from calling me with SPECIAL OFFERS except the expense. The various telemarketing trade groups persist in the empty argument that "No business would make calls that annoy customers". The very popularity of the "Do Not Call" list belies that argument. I also do not look forward to registering with the separate "Do not call" lists of each restaurant chain, convenience store, gas station, grocery store, etc. that I have made a purchase from. Until the definition of EXISTING BUSINESS RELATIONSHIP is tightened to exclude that McDonald's in Turlock that I stopped at last year and it's ilk I oppose any rule change that lowers the cost of making telemarketing calls. Another option would be a federal "No Prerecorded Calls" registry. Wtih regard to the DMA petition, there are no technical reasons that automated dialing software can't meet the 3% per day/per campaign numbers. I suspect that what they are really seeking is the flexibility to ignore the regulations temporarily when they need to meet end-of-month call quotas. I think the burden of sufficient staffing and planning should lie with the DMA members rather than the general public.