|Received:||11/6/2006 5:14:07 PM|
|Subject:||Telemarketing Sales Rule|
|Title:||Request for Public Comment|
|CFR Citation:||16 CFR Part 310|
Comments:The requirement for written authorization poses an impossible barrrier to inexpensive services. I provides an opt-in service that makes outbound calls to subscribers; I've been providing this service at no charge for several years, and in 2007 I intended to make it available for subscribers but use it to solicit funds for charitable organizations. A web-based subscription service automates the process and drives the costs of a subscription to almost nothing; voice confirmation of opt-in reduces the possiblity of harrasement almost to nothing. But if I require written confirmation from subscribers, I will not be able to afford to run this service. Instead, the FTC should adopt rules that require voice confirmation of requests to opt-in and an "always-on" method to opt out that can be used at the very beginning of the call. Furthermore, the FTC should strictly enforce existing rules against solicitation.