|Received:||12/15/2004 2:35:24 PM|
|Subject:||Trade Regulation Rule on Telemarketing Sales|
|Title:||Notice of Proposed Rulemaking, Request for Comment|
|CFR Citation:||16 CFR Part 310|
Comments:I STRONGLY object to the adoption of any amendment to the Telemarketing Sale Rule (the "Do Not Call List") that allows for any relaxation of the rules in favor of telemarketers. The proposed amendment by the Direct Marketing Association is a violation of the intent of the rule and weakens the position of consumers who do not want to be pestered by unsolicited calls -- pre-recorded or otherwise. I specifically OBJECT to the two following proposed amendments: 1) to create an additional call abandonment safe harbor to allow telemarketing calls that deliver a prerecorded message to consumers with whom the seller on whose behalf the calls are made has an established business relationship; and 2) to amend the TSR’s call abandonment safe harbor provision that currently requires use of "technology that ensures abandonment of no more than three (3) percent of all calls answered by a person, "measured per day per calling campaign" substituting the phrase "measured over a 30-day period.". Both of these amendments would weaken consumer protections and are unacceptable. I strongly advise the FTC to REJECT these proposed amendments.