| Comment Number: | OL-100062 |
| Received: | 9/3/2004 10:27:59 AM |
| Organization: | SmithBucklin Corporation |
| Commenter: | Steven Kemp |
| State: | DC |
| Agency: | Federal Trade Commission |
| Rule: | Definitions, Implementation, and Reporting Requirements Under the CAN-SPAM Act (NPRM) |
| Docket ID: | [3084-AA96] |
| No Attachments |
Comments:
Dear Sirs: I serve as the executive director for two national membership organizations and have become aware of the FTC's proposed rules under the CAN-SPAM Act. I fear these rules would severly damage the ability of non-profit organizations to communicate with our members. We find that we rely on email communications with our members for reasons of efficiency and cost savings. As the overwhelming bulk of emails between nonprofit organizations and their members are transactional or relationship based under the definition of the CAN-SPAM Act, I urge the Commission to NOT implement new rules which would restrict how we need to communicate with our membership. I implore the Commission to specifically provide in its regulations that emails transmitted by a tax exempt, non-profit organization to a current member or sponsor regardless of its content not be subject to the CAN-SPAM Act because these types of communications are transactional or relationship messages as long as the messages are in line with the organization's tax exempt purposes. I commend the Commission on its goal of relieving us of the overwhelming quantity of email that is clearly obnoxious, unwanted junk but there must be an exemption for nonprofit organizations who do so much good for U.S. trade and commerce. Many nonprofit organizations have extremely limited resources including human resources. Therefore, placing restrictions on how we must communicate with our members would adversely affect how we go about fulfilling our important missions. Sincerely, Steven Kemp, CAE Association Executive SmithBucklin Corporation