Notice of Proposed Rulemaking Seeking Public Comment on Proposal to Ban Payment Methods Favored in Fraudulent Telemarketing Transactions; FTC Matter No: R411001
I wish to have this rule reconsidered. Parts of it have merit. The parts that do not have merit are regulating the types of payments that can be accepted. Although it is very sad when a senior citizen or someone else that may not understand what is occurring, gets taken for their savings, this regulation puts unfair burden on community banks and credit unions. This would occur because debit and credit cards would still be allowed and the use would increase because other forms of payment would be prohibited. Debit and Credit cards are primarily issued through MasterCard and VISA. The chargeback rules are generally in favor of the merchant and the zero liability rules created by both MasterCard and VISA favor consumers. This means the banks are held responsible when a consumer claims fraud. The merchant is not held responsible. This will put more banks in jeopardy of going out of business and will reduce competition in the US banking environment. There are already several banks that are “too big to go out of business.” This will create further problems in the U.S. Economy. This proposed rule would be better suited to eliminate telemarketing calls or restricting the proposal to the 5 bulleted items above.