FTC Workshop Analyzing Negative Option Marketing #527292-00003

Submission Number:
Kelm, Bill
Initiative Name:
FTC Workshop Analyzing Negative Option Marketing
Matter Number:


I have studied this "Auto-Renewal" issue fairly well as a consumer advocate, and I've come to the conclusion that unless many "return receipt" e- mail reminder notices are sent out well in advance of renewal dates, auto-renewal has more negatives than positives for the consumer, and maybe even sellers if they have easily cancelable subscriptions without any "pro ration". Even if a reputable company like Consumer Reports sends more than their once a year subscription reminder e-mail, if the subscriber is on a long vacation, has his Internet service down for some reason ( my FiOS lifeline for Internet, phone, and TV was recent cut somehow, and they were all "out of service"), or is just ignoring his e-mails due to "divorce depression", etc., then he may be billed automatically for something he no longer wants. Then, even if it is easy to cancel a month later without pro ration when the buyer gets his PayPal or credit card bill, then he has to monitor future bills to make sure the seller follows through in a timely way with the adjustment credit. He also loses the use of those pending credited funds until the adjustment comes through. I blogged about this in ""Auto-Renewal" Complaints May Lead To FTC Rules" ( http://www.brokerblogger.com/brokerblogger/2007/01/autorenewal_com.html ) = I AM NOT TRYING TO PROMOTE MY BLOG, BUT ONLY TRYING TO HELP AVOID THE GROWING NUMBER OF COMPLAINTS (I have a "Google Alert" for the keywords "Auto-Renewal" and "Automatic Renewal" and see many complaints that way) I also just wrote the details of my "return receipt" strong suggestion in "A Solution For "Auto-Renewal" and New FTC's Negative Option Marketing Emphasis" ( http://www.brokerblogger.com/brokerblogger/2007/02/a_solution_for_.html } = I hope Lydia Parnes, FTC’s director of the Bureau of Consumer Protection gets a chance to read my suggestion, as I believe it is the only way consumers can be protected! I sent a copy of this to negativeoption@ftc.gov as well as smbiz@mail.house.gov, info@nclnet.org, and ben@consumerist.com. Sincerely, Bill KelmFederal Trade Commission