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August 16, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 Seventeenth Street, N.W.
Washington, D.C. 20429
To the FDIC:
I am a consumer and write to comment on the proposed Affiliate
Marketing Rule.
I strongly feel that the final regulations should provide that when a
consumer has opted out, the affiliates of the company which has the
relationship with the consumer should be prohibited from circumventing
the opt-out by instructing that company (with the consumer relationship)
or another affiliate to make or send solicitations to the consumer on
their behalf, assuming the affiliates would not be permitted to make or
send such solicitations as a result of the consumer's election.
Businesses should not be permitted to circumvent a consumer's desire to
opt-out in this way or otherwise. The law already provides business with
great opportunities to share consumer data -- the regulation should not
create additional opportunities.
I believe that the final regulations should not allow businesses to
send a joint notice that does not list each affiliate participating in
the joint notice by its name, even if each affiliate shares a common
name. The joint notice should list each affiliate participating in a
joint notice by its name and its specific line of business. If a
business wants to extensively share a consumer's sensitive information,
it should be required to tell the consumer specifically where it is
going so that, if the consumer objects to such sharing, he or she may
discontinue the consumer relationship with that affiliate family.
In addition, I feel that the scope of the communications that do not
meet the proposed definition of "solicitation" should not be expanded –
it is sufficiently broad.
Sincerely,
Lily E. Jelalian
144 Bloomfield Avenue
Paterson, NJ 07503
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