Comment Number: OL-100067
Received: 9/9/2004 5:26:38 PM
Organization: New Jersey League of Community Bankers
Commenter: James Silkensen
State: NJ
Agency: Federal Trade Commission
Rule: Definitions, Implementation, and Reporting Requirements Under the CAN-SPAM Act (NPRM)
Docket ID: [3084-AA96]
No Attachments

Comments:

Membership organizations such as 501(c) 6 trade associations should fall under the transactional or relationship category of e-mail and should therefore be exempt from the CAN-SPAM Act provisions. Members of the New Jersey League of Community Bankers and other membership organizations voluntarily join as members and as members expect to be kept informed of the organization's activities. That includes information on products and services offered to those members as a result of their membership. If the members were not interested in the products and services, they would not have joined the association. We urge the Federal Trade Association not to place a new and very much unnecessary regulatory burden on membership organizations.