NATIONAL ASSOCIATION OF ATTORNEYS GENERAL
2030 M Street, N.W. 8th Floor
WASHINGTON, D.C. 20036
Phone (202) 326-6019
Fax (202) 785-0287
http://www.naag.org
JAMES E. MCPHERSON
PRESIDENT
Executive Director
JON BRUNING
Attorney General of Nebraska
PRESIDENT-ELECT
ROY COOPER
Attorney General of North Carolina
VICE PRESIDENT
ROB MCKENNA
Attorney General of Washington
IMMEDIATE PAST PRESIDENT
PATRICK C. LYNCH
Attorney General of Rhode Island
October 23, 2009
Federal Trade Commission
Office of the Secretary
Room H-135 (Annex T)
600 Pennsylvania Avenue, NW
Washington, DC 20580
Re:
Telemarketing Sales Rule - Debt Relief Amendments
Matter No. R411001
Dear Secretary Clark:
The Attorneys General of Alaska, Arizona, Arkansas, California, Colorado, Connecticut,
Delaware, Florida, Georgia, Guam, Hawaii, Idaho, Illinois, Iowa, Kansas, Maine, Maryland,
Massachusetts, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire,
New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode
Island, South Carolina, South Dakota, Tennessee, Texas, Vermont, Washington, West Virginia,
and Wyoming (“the States”), submit the following comments on the Proposed Rulemaking to
amend the Federal Trade Commission’s (“FTC”) Telemarketing Sales Rule (“TSR”), 16 C.F.R.
Part 310, to address the sale of debt relief services.
I. INTRODUCTION
On August 19, 2009, the FTC published its Notice of Proposed Rulemaking (NPRM)1 in which it
considers amending the TSR to address the sale of debt relief services. The States applaud the
FTCs undertaking this rulemaking because, as detailed below, the actions of debt relief
companies have resulted in substantial increases in consumer complaints being filed with the
States across the country. Further, the severity of the harm complained of by consumers is
reflected in the fact that over the past five years, twenty-one states have brought at least 128