16 CFR Part 429, Rule Concerning Cooling-Off Period For Sales Made At Homes Or At Certain Other Locations, FTC File No. P087109 #563691-00005 

Submission Number:
563691-00005 
Commenter:
Jane Driggs
Organization:
Better Business Bureau of Utah, Inc.
State:
Utah
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

The Better Business Bureau of Utah receives thousands of complaints annually regarding door-to-door sales. The sales people sell items including alarm systems, pest control, cleaning products, magazines and even meat door-to-door. The FTC Cooling off Rule provides consumers with some measure of safety, as intended. Complaints to the BBB regarding these types of businesses allege misrepresentation and significant pressure to purchase immediately. Sometimes consumers even feel threatened or misrepresentations are used such as affiliations or endorsements, so the consumers sign the contracts or purchase products under false pretense or duress just to have the sales person leave. The current dollar threshold of $25, while low, allows consumers three days to really look over the contract or product and check out the businesses to determine exactly what was purchased or to read the fine print. Raising the limit to $130 will eliminate most door-to-door sales done in Utah, thereby eliminating the need for the rule and its protection for the most vulnerable consumers. Last year alone the BBB in Utah received more than 130,000 inquiries on Utah businesses that actively sell door-to-door. Consumers do check on businesses, but don’t always feel comfortable doing so or able to while the sales person is at the door. We hope that you will keep the dollar threshold where it currently is, so that consumers will be protected and if pressured they will be able to enact the Cooling off Rule.