As General Counsel of a small business that complies with the TSR, but would not be affected by any of the modified provisions I would like to file this comment on behalf of my company. The amendments suggested regarding methods of payment will have a positive effect on consumers. Businesses should never be given direct access to a consumers accounts, this creates a perfect scenario for fraud and other deceitful actions to occur. The biggest concern I have is with companies claiming to offer recovery services. I do not believe the commissions proposal goes far enough. Companies should be required to wait longer than 7 days before collecting a fee when offering these services, or the commission should not allow a non attorney to offer this type of service. From my experience the new arena of fraud is being created through recovery companies. These companies prey on victims of work-at-home and other similar companies who have been defrauded for thousands of dollars and are looking for a place to turn. The recovery services offer them guaranteed recovery all they have to do is provide copies of credit card statements, contracts, and email correspondence. The company may state they may take the case for a one third contingency. However, there will never be a recovery. The commission has to step up and take a real stance against these predatory companies who prey on the already weak and vulnerable. I am attaching an example of the emails a defrauded may get from one of these clients. It is important to keep in mind the majority of these services are not offered by attorneys. I have copy and pasted the email into a word document to protect the identity of the recipient.
Notice of Proposed Rulemaking Seeking Public Comment on Proposal to Ban Payment Methods Favored in Fraudulent Telemarketing Transactions; FTC Matter No: R411001 #00009
Notice of Proposed Rulemaking Seeking Public Comment on Proposal to Ban Payment Methods Favored in Fraudulent Telemarketing Transactions; FTC Matter No: R411001