| Comment Number: | OL-111679 |
| Received: | 12/21/2004 5:57:16 PM |
| Organization: | Sponsor Reps, Inc |
| Commenter: | Doug Thornton |
| State: | WA |
| Subject: | Trade Regulation Rule on Telemarketing Sales |
| Title: | Notice of Proposed Rulemaking, Request for Comment |
| CFR Citation: | 16 CFR Part 310 |
| No Attachments |
Comments:
RE: FTC/FCC Abandonment Rate I’m writing in regards to the decision on whether to have the 3% abandonment rate based on a day-by-day/project-by-project basis or over a 30-day basis. It is our belief that the FTC and FCC are interested in reducing abandonment rates to protect the public from nuisance calls, not to add unnecessary burden and expense to business. Measuring abandonment rate on a daily/project basis creates much more complication and expense that must be passed onto consumers without reducing the overall abandonment rate as compared to a monthly abandonment rate. Being able measure and control abandonment rates on a daily/project basis instead of over a 30-day basis may not be possible with today’s technology, but will definitely be financially burdensome to both businesses and consumers, very expensive to enforce, and provides no added benefit to the consumer. Doug Thornton CEO Sponsor Reps, Inc