Pay-Per-Call Rule Review: Reponse to Notice of Proposed Rulemaking: 16 C.F.R. Part 308, FTC File No. R611016 #13

Submission Number:
Network Telephone Services
Initiative Name:
Pay-Per-Call Rule Review: Reponse to Notice of Proposed Rulemaking: 16 C.F.R. Part 308, FTC File No. R611016

Before the
Washington, DC 20554

In the Matter of

Pay-Per-Call Rule Review

FTC File No. R611016


Network Telephone Services, Inc. (NTS) is a service bureau and information provider of audiotext services located in Woodland Hills, California. NTS has been in continuous operation in the pay-per-call business since 1988.

NTS is going on record with the Federal Trade Commission (FTC) in its Pay-Per-Call Rule Review with our support of the detailed comments that are being filed by both the TeleServices Industry Association (TSIA) and the Billing Reform Task Force (BRTF). NTS encourages the FTC to strongly consider the comments of these two (2) industry trade groups representing different segments of the pay-per-call business. The comments of both the TSIA and the BRTF identify how the consumer protection goals of the U.S. Congress can be met without overly restricting the pay-per-call industry's ability to fairly conduct its business.

In particular, NTS strongly urges the FTC to expand the allowable methods of payment that may be used by consumers in "presubscription" pay-per-call transactions, whether or not such cards or payment methods are subject to the Truth in Lending Act. The regulations propounded by the Federal Communications Commission and the FTC following the enactment of the Telephone Disclosure and Dispute Resolution Act of 1992 (TDDRA) provide detailed and proven procedures for consumer dispute resolutions. These TDDRA dispute resolution rules were modeled from the same dispute resolution rules of the Truth in Lending Act (TILA) and offer substantially similar protections to consumers. Therefore, if a payment method is not subject to TILA (e.g., debit cards) but the pay-per-call transaction is subject to TDDRA rules, consumers would be able to avail themselves of the same dispute resolution rules for pay-per-call transactions that are available for 900 calls or standard credit card calls. By accepting such a floor of consumer protection, the FTC can protect consumers while also making available additional billing options for the consumer.

Respectfully submitted,

Network Telephone Services, Inc.

March 12, 1999

By ______________________