| Comment Number: | OL-113007 |
| Received: | 1/10/2005 7:18:51 AM |
| Organization: | |
| Commenter: | Robert Baxter |
| State: | CA |
| Subject: | Trade Regulation Rule on Telemarketing Sales |
| Title: | Notice of Proposed Rulemaking, Request for Comment |
| CFR Citation: | 16 CFR Part 310 |
| No Attachments |
Comments:
I do not agree with the proposal to change the measurement parameter from per day to per 30 days. This is clearly intended to dilute today's current standard into something that is more favorable to telemarketers and to the detriment of people who do not want to be bothered by them. The DMA's Petition statement, "meeting the 3% benchmark under the FTC's per day, per calling campaign standard presents a much greater compliance obstacle than meeting the FCC's abandoned call standard. Marketers who use predictive dialing technology are having difficulty configuring their software to comply with the FTC's per day, per calling campaign 3% standard." is quite misleading. Some telemarketers routinely ignore the current regulations and continue to make telemarketing calls. Most use callerID blocking to conceal their identieis and plead ignorance when confronted with violating the DO NOT CALL regulations. This proposed rulemaking is only intended to give more lattitude for telemarketers to be able to make more telemarketing calls; especially the ones who are presently making telemarketing calls in violation of the existing regulations. Over the last three months, my answering machine has recorded 7 pre-recorded telemarketing phone calls from organizations that are neither policital parties, charitable organizations nor entities with whom I have had any business dealings. Further, I have had approximately 10 live telemarketing phone calls also from organizations that are neither policital parties, charitable organizations nor entities with whom I have had any business dealings. DMA and all telemarketers need to follow the law first before asking for modifications to existing regulaitons. People in this country have the right to not be bothered. There are no rights for people including DMA and telemarketers to intrude into people's lives and the current law has gone a long way towards making that a greater reality. If adopted, the proposed rulemaking represents several steps backwards. As a reminder to the FTC, your agency is not the servant of the entities that you are charged with regulating. Your responsibility is to the American people as a whole. Anyone with half a brain should have no difficulty in determining that many aspects of the proposed rulemaking offer no real benefit to the American people as a whole. Regards, Robert Baxter Phone: (310) 515-0223