| Comment Number: | OL-106159 |
| Received: | 12/5/2004 9:53:40 PM |
| Organization: | Applied Financial Technology |
| Commenter: | Michael Bykhovsky |
| 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:
A telemarketer's decision to use a pre-recorded call system indicates an expectation of a very low success rate. In other words, if one out of every ten calls is converted into a transaction, then it's worth to use a live operator, if it is one out of a thousand, then only the pre-recorded method is profitable. So a pre-recorded system utilization indicates that a telemarketer is willing to disrupt 1,000-10,000 lives for a sake of a single sale. That method should clearly be prohibited under all circumstances. If a customer is worth being disturbed, at least he should be disturbed by a live operator. Sincerely, Michael Bykhovsky, CEO