| Comment Number: | 516302-00003 |
| Received: | 5/24/2005 11:01:32 AM |
| Organization: | Wells Fargo & Company |
| Commenter: | Peter McCorkell |
| State: | CA |
| Agency: | Federal Trade Commission |
| Rule: | Telemarketing Sales Rule Fees |
| Docket ID: | 3084-0098 |
| No Attachments |
Comments:
Wells Fargo & Company ("Wells Fargo") urges the Commission to reconsider the proposal to continue to provide free access to the first five area codes of the national do not call registry. It is evident from the figures contained in the Commssion's notice of proposed rulemaking and request for public comment that a small number of large users are subsidizing a much larger (and growing) number of small users. And those figures significantly understate the full cost of do not call compliance to large users, since there are still a number of states which require telemarketers to also pay for access to their own, state-specific lists. The cost of paying for access to the first five area codes - $185.00 according to the pro forma figures supplied by the Commission - would hardly be a significant burden on even the smallest of businesses. However the cost of subsidizing more than 50,000 such businesses is a significant burden on the relatively small number of paying subscribers, and the even smaller number of subscribers to the entire registry. Wells Fargo does support continuing to provide free access to "exempt" entities since it is safe to assume that few if any such entities would access the list at all if they were required to pay for such access. Respectfully submitted, Peter L. McCorkell Senior Counsel