Submission Number: 00017
Received: 7/26/2013 7:58:16 AM
Commenter: John Frank
Agency: Federal Trade Commission
Initiative: Notice of Proposed Rulemaking Seeking Public Comment on Proposal to Ban Payment Methods Favored in Fraudulent Telemarketing Transactions; FTC Matter No: R411001
Attachments: No Attachments
The proposed changes to this rule will kill free enterprise and preclude legitimate business from being conducted using a pre-authorized draft or rcc. The change here is just like blaming the gun and not the person who pulls the trigger in the case the bad telemarketer. Rcc return rates are easily and readily tracked and provide receiving consumers and banks with much more information about the transaction. Why not put in a better framework for their use such as requiring an inline recording and url information as well as easily identifiable cancellation and customer care I formation. The RCC has been around for many many years and provides space for a great deal of information which is the primary driver for the use of this payment mechanism. Customers are held to return rate standards and terminaged if standards are not met. In addition return rates for a consumer driven transaction in the check or ach world are always going to be higher as consumers provide bad data in the credit ard world there is the ability for immediate response that is just not available on the bank side. Dont throw the baby out with the bath water the rcc is not the problem prohibiting its use will only stifle its use across all industries you have businesses who cannot originate ach because of bank credit standards so they use rcc... rcc items are actually less restrictive from a return standpoi t and easier for consumers to return providing a longer return window. Rcc is just a vehucle put in standards guidelines for their use inckuding monitoring standards whike making it difficlt for the fraudulent telemarketer to do business. How about requiring alk telemarketers to register providing all product and fullfillment details for what they are selling and do tye same for fullfillers then make certain the fullfillers are sending product and legitimate and audit both this would reduce or nearly eliminate a great deal of the fraud then if a payment processor or bank does business with an entity not on the registration fine the hell out of them and shut them down.