Submission Number: 00019
Received: 12/16/2010 6:30:29 PM
Commenter: Gary Connor
Organization: DirectLine Technologies, Inc.
Agency: Federal Trade Commission
Initiative: 16 CFR Part 310: Telemarketing Sales Rule
Attachments: No Attachments
To paraphrase the intent of the FTC's Telemarketing Sales Rule (TSR) proposed possible changes, you are asking for help to formulate MORE regulations in order to address problems with those businesses or organizations THAT DO NOT FOLLOW YOUR REGULATIONS. The current rules are sufficient to allow consumers and law enforcement to identify those telemarketing companies that comply with FTC rules and regulations.
There is no need for additional rules or regulations. THERE IS SIMPLY A NEED FOR BETTER ENFORCEMENT against those companies that FAIL to follow the existing rules and regulations. Those who are not in compliance with current rules are not suddenly going to comply with an even more onerous set of rules.
While it is nice to provide the legislature and the citizenry with the perception that you are being more proactive, you are simply ignoring the real issue of non-compliance to place an additional burden on those who maintain compliance.
More rules might be good public relations, but will definitely be a bad economic move, bad business, and will do ABSOLUTELY NOTHING to increase compliance by those entities that currently do not comply.