From: Richard Storey firstname.lastname@example.org
The problem with all of your rules is that none of them are fool-proof and they amount to nothing other a case of voluntary honesty by those who are already honest or those who are just too lazy to be a tiny bit creative. This means that, once again, government is injecting itself into an issue and providing taxation through regulation instead of legislation and nothing really gets solved. The idea that it is better to do "something", rather than "nothing", is bogus when the something you do creates more problems than it solves and you're still left with the same problem you started with.
Here are the problems with each of your proposals:
1. Consent forms. There is no possible way to prevent fraud in the case of a consent form because there is no way to verify whether the parent's signature on the form is genuine.
2. Credit card verification. It costs money each time you conduct a transaction of this kind. Why do you think that web site hosts or the credit card system is doing business? It is to make money, not to provide their services to verify someone's identity for non monetary actions such as the one you propose. This has the effect of transferring the cost of verification onto a third party.
3. Toll free number. First, why should you dictate that the number be toll free? What gives you that right? Second, this is a moron's idea which says that the site must somehow be able to determine the age of the party calling and that the person is, in fact, the child's parent. This cannot be done.
4. Email verification. I don't know of any digital signature firms that give away free certificates. The good ones cost $100 or more, usually, and cheap one's can be faked by supplying false identity. The bottom line is that you are proposing requirements which significantly burden the information provider, but are not effective, merely for the sake of taking some kind of action. The only proposal you've made that even comes close to being effective is the digital certificate provided as I.D. via email. This, however, would have the effect of placing the majority of the burden, financial and otherwise, upon the user or parent, which is right where it belongs. It still, however, will not be fool-proof because you will not make the requirement that this be the only method available. Why? Because it will cost money for the user and it will require a significant amount of personal involvement on the part of the parent.
The commission's solutions are highly faulted and it is better that the FTC do nothing at this time rather than act in a manner so typical of the federal government by raising the financial burden of business via nonsensical regulations.