| Comment Number: | OL-102924 |
| Received: | 11/28/2004 2:12:28 AM |
| Organization: | |
| Commenter: | Joe Kislo |
| State: | MA |
| Subject: | Trade Regulation Rule on Telemarketing Sales |
| Title: | Notice of Proposed Rulemaking, Request for Comment |
| CFR Citation: | 16 CFR Part 310 |
| No Attachments |
Comments:
To the FTC, While the forces of the marketing world are strong, you must remember to whom you are responsible. You are not responsible for facilitating the telemarketing companies success at the cost of those who you serve. Adopting policies allowing prerecorded or non-human telemarketing will increase the telemarketing burden on the people you are trying to protect *geometrically*. Such a modification would change telemarketing rules in such a radical fashion, you risk bringing the 'email spam' problem to the telephones across the US. Telemarketing firms are not going out of business, and they do not need government giveaways. Additionally, modifying the rules to allow 3% call abandonment over a 30 day period is insanity. Making this modification, as I understand it, will allow telemarketing firms to run up abandonment rates (allowing massive parallel calling), then only at the end of the month start a more conservative approach to keep the adbandonment rate at the legal limit. Think about why they are asking you to modify this rule aswell. It *WILL* lead to more abandoned calls, it has to. They will now have the ability to keep their call rate highenough to hit the legal limit, and if they should exceed it, they will have the responsiveness to get it back to legal limits before the 30 day period is up. With a daily approach, they have to be considerably more concervitive from the start. By asking you to make this change, they are asking for another government handout, and there is only one person who pays for these. The consumer who you are trying to protect. Thanks, -Joe