Comment Number: 525547-00144
Received: 11/14/2006 2:15:22 PM
Organization: TCN Voice Broadcasting
Commenter: Michael Foley
State: UT
Subject: Telemarketing Sales Rule
Title: Request for Public Comment
CFR Citation: 16 CFR Part 310
No Attachments

Comments:

There is an area between NOTICES and TELEMARKETING that must be addressed. For example, small town newspapers use pre-recorded messages instead of costly mailers or phone calls one-by-one, to let their subscribers know when their subscriptions need to be renewed. with a push of a button, they are directed to customer service, and that revenue is maintained. Customers largely have responded postively to this and we have very little complaint about this function. They are not calling people to sign them up for anything NEW, it is simply a call to maintain what they already have. Not an annoying cold call, but not just a notice either. So where does this leave these papers? Newspapers in general have experienced declining readership, and the smaller papers in particular don't have enough money to staff a call center full of people, nor can they fund all that postage to send letters. Voice Broadcasting is in many cases the best way they can stay in business. Without this cost-effective method of renewal, many papers would be in dire situations. I would propose that there should be some kind of provision made for companies to use messages for MAINTAINING current relationships, and not cut out transactions all together. Telemarketing for business is one thing, but simply reminding and maintatining is another. PLEASE RESPOND Michael Foley TCN Voice Broadcasting