|Received:||4/2/2004 2:24:48 PM|
|Organization:||National Tour Association|
|Agency:||Federal Trade Commission|
The National Tour Association is an organization of 4000 tourism officials in the US and worldwide. We are concerned that implementation of the Act could seriously impact the ability of membership associations to solicit sponsorship opportunities, market association-specific research, and solicit registrations for conferences and seminars. NTA strongly feels that nonprofit communications should be outside of these regulations and that "existing business relationship" be interpreted as pertaining to existing members of the association as well as members for which a prior business relationship existed. As a membership association, it is necessary for us to maintain communications with current and former members and, do to our nonprofit status and the costs associated with maintaining services for these members, the communications must necessarily have a commercial component. Nonprofit trade associations, by simple reasons of efficiency, must engage in mass emailing of members, past members and prospective members. These communications are confined to tourism businesses and are not "consumer" messages. NTA feels that targeted communications of a commercial nature should not be constituted as "spam." In addition, because trade associations tend to have small staffs, an extension of the 10 day "opt-out" provision would be welcome. NTA would like to see a 15 day window for opt-out. Finally, members expect to receive communications from an organization to which they have (or have had) an affiliation. It would be counterproductive from the organization's standpoint to have members to which they are unable to communicate. That is why we support as liberal an interpretation as possible to facilitate association-member communication. NTA strongly supports laws to regulate unsolicited commercial email broadcasts, especially those of a pornographic or provocative nature. But we hope that in creating such regulations, the ability of nonprofits to communicate with members (past, present and potential) is not compromised. Thank you for your time and attention.