16 CFR Part 429, Rule Concerning Cooling-Off Period For Sales Made At Homes Or At Certain Other Locations, FTC File No. P087109 #563691-00003 

Submission Number:
563691-00003 
Commenter:
Don Gowen
Organization:
Gowen Consulting
State:
Alabama
Initiative Name:
16 CFR Part 429, Rule Concerning Cooling-Off Period For Sales Made At Homes Or At Certain Other Locations, FTC File No. P087109

Based on 50 years experience in the consumer finance industry and having been acquainted with and serviced door-to-door sales by slected retail dealers, I submit that the Commission should retain the $25.00 cancellation rule for the continued protection of the consumer from predatory sales schemes. While inflation over the past 40 years may have affected the original cap amount, the primary consideration should not be for the selling company but for the consumer. In most cases, the consumer does not know where to locate the sales person or company when a fraudenlent practice occurs and therefore, regardless of the amount - $25.00 or $130.00 - the consumer should be provided with the option to cancel the purchase made in a door-to-door sale. Only for the exception of activities like girl scout cookie sales, etc. should the $25.00 cap be retained. Don Gowen, [redacted], Alabama