|Received:||11/3/2006 4:12:17 PM|
|Organization:||Healthcare Technology systems|
|Subject:||Telemarketing Sales Rule|
|Title:||Request for Public Comment|
|CFR Citation:||16 CFR Part 310|
Comments:Dear Sir or Madam, Interactive automated telephone calls are superior to simple pre recorded 'informational' messages or 'live agent' systems. They are more consistent, understandable, and auditable for compliance with regulations. Requiring written signatures, rather than accepting Internet or e-mail to sign-up permission for interactive telephone services seems neither practical nor balanced fairly. Automated caller interactivity allows easy queries/requests or information, no-pressure opting out of calls, and even registration of complaints with just a touch of a button or speaking single words or phrases. As a consumer, I like getting computer-automated reminders of scheduled and newly available services. I also find it easier to simply hang-up on such systems with less personal reluctance than doing the same to a 'live' outsourced calling agent. Please carve out interactive automated services from your regulations, with the reasonable protections that a button push or spoken phrase would allow me to be placed on that company's Do Not Call List. In an automated telephone system, enforcement of such requests could be documented and enforced through logged records. 'Live' agent systems cannot be fairly audited for compliance as easily since they depend upon agents to accurate recording the telephone interchange. James C. Mundt, PhD VP Research & Development Healthcare Technology Systems, Inc.