|Received:||11/6/2006 3:42:26 PM|
|Organization:||IVR Concepts, LLC|
|Subject:||Telemarketing Sales Rule|
|Title:||Request for Public Comment|
|CFR Citation:||16 CFR Part 310|
Comments:This proposal will selectively impact automated call operations. While centers with live agents will be allowed to call on existing customers of clients, fully automated centers will not. I fully agree with strong limits on predictive dialers (I personnaly detest them), however automated systems that are properly designed have no difference to live agents making the same call. This proposal will limit informational calls to customers that have an 'up-sell' component, even if it is a small portion of the entire message. For example, (by my reading) a call to notify a customer that a service request has been completed would not allow a compnay to mention other services that are complementary to the service. Thank you for your consideraton of this matter - please vote against the proposal.