EPIC, NCLC, and Partners Comment on FTC Telemarketing Sales Rule

August 4, 2022

EPIC and NCLC, joined by twelve other consumer advocacy and legal aid organizations, submitted comments to the Federal Trade Commission (FTC) regarding two proposed sets of changes to the Telemarketing Sales Rule (TSR), which protects consumers from telemarketing fraud.

The first set of comments addresses recordkeeping requirements for telemarketers, calls to donors, and misrepresentations during telemarketing calls directed to businesses (or business-to-business calls).

The second set of comments addresses topics such as “free trials” that automatically become paid subscriptions, a consumer calling a telemarketer for tech support, business-to-business calls generally (i.e., not limited to misrepresentations), differences between the TSR and the FCC’s Telephone Consumer Protection Act, prohibiting peer-to-peer and cryptocurrency payment methods in telemarketing transactions due to consumer refund difficulties, and applying the TSR to text messages.

EPIC has long advocated for the FTC to use its legal authorities to combat harmful data practices and routinely files comments with the agency. EPIC and NCLC have jointly filed numerous comments to the Federal Communications Commission on matters involving illegal and unwanted robocalls and other phone-based scams.

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