|Received:||11/30/2004 12:59:42 AM|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:Please do not create the proposed additional safe harbor or amend the existing safe harbors. Often a supposed "established business relationship" is merely one transaction conducted a long time ago; our modern era of malls and mail order catalogs presents us with many fleeting merchant-customer relationships. 150 years ago, one might have a long term relationship with one or a few shopkeepers; these days we don't have deep relationships with any merchants. As for changing the per-day requirement to per-30 days, this seems hasty to me. Let's give the per-day requirement at least another year to see how it really works out for customers and how much of a burden it truly is for telemarketers. With modern automatic call distribution and similar systems, I see no technical reason why measurement on a daily basis is more difficult than on a 30 day basis.