| Comment Number: | OL-100014 |
| Received: | 10/27/2004 6:21:38 PM |
| Organization: | none |
| Commenter: | Edward Connors |
| State: | OH |
| Agency: | Federal Trade Commission |
| Rule: | Prescreen Opt-Out Disclosure |
| Docket ID: | [3084-AA94] |
| No Attachments |
Comments:
1. I oppose granting of exceptions to the effective date especially for small business entities. Larger entities might utilize "front organizations," subcontractors, or free-lancers to circumvent the requirements of the proposed rule. 2. All membership organizations that participate in affinity-group marketing of credit cards should be required to comply with the proposed rule. For example, the Ohio State University Alumni Association (Columbus Ohio) made its donor mailing list available to a credit card subsidiary of a bank recently, without prior notice and approval of past donors to the Alumni Association. MBNA America is notorious for soliciting many such affinity-group lists. I am concerned that "matched" donor data may eventually migrate into huge linked databases such as those of Acxiom or TTIC, unless the opt-out requirement under FCRA encompasses the affinity-group credit-card offeror who mails out for MBNA, ostensibly a membership organization's offer, as shown on the outer cover of the direct-mail piece. 3. The proposed effective date is appropriate. 4. Type fonts for the notices should be highly readable fonts such as those utilized by publishers of large-print schoolbooks. There shall be no Old English or novelty fonts in these notices. 5. Additional information should be excluded from the proposed notices. Opt-out should be described in neutral language, and misleading statements that purport to warn that a service or benefit will be denied should be prohibited. The proposed rule ought to be amended to make this plain, with examples of non-compliant language included. 6. Some states have adopted statutes that require minimum font sizes in insurance policy documents. Ohio has such a statutory requirement. Nothing in the proposed FCRA rule should be less restrictive than the minimum font sizes stipulated in such state statutes. This is my comment on Federal Trade Commission Title: Prescreen Opt-Out Disclosure Subject Category: FACT Act -- Notice of Proposed Rulemaking (NPRM) Docket Id: [3084-AA94] CFR Citation: 16 CFR Parts 642 and 698 Published: October 01, 2004 [FR Doc. 04-22039]