Comment Number: OL-102724
Received: 11/28/2004 12:19:01 AM
Organization:
Commenter: Ira Kaufmana
State: CA
Subject: Trade Regulation Rule on Telemarketing Sales
Title: Notice of Proposed Rulemaking, Request for Comment
CFR Citation: 16 CFR Part 310
No Attachments

Comments:

As to '(3) percent of all calls answered by a person, 'measured per day per calling campaign' substituting the phrase 'measured over a 30-day period.' I would recommend the changed phrase to be "measured over a 30-day period or the calling campaign, whichever is less" For the expansion of the calling list, this would only make sense if, 1) the caller was running from an IVR system that would allow opt out by touch tone and 2) the opt out option was presented as the second item provided, the first being the identity of the calling company. Any other approach makes the opt out more difficult and time consuming than needed.