Advisory opinion letter: the preemptive effect of the Commission s Trade Regulation Rule Providing a…
87 F.T.C. 1452 · Sept. 19, 1974 ·
source volume section (87 F.T.C. 1452)
Text is machine-OCR of the printed volume and may contain errors. Advisory opinions are the Commission's views on proposed conduct, not binding orders.
September 19 , 1974 Dear Secretary Tobin:
On June 6, 1974, the Direct Selling Association (DSA) filed a request for an advisory opinion relating to the preemptive effect of the Commission s Trade Regulation Rule Providing a Cooling-Off Period for Door-to-Door Sales (16 CFR 429.1). On July 26 1974, DSA filed a petition to amend the above-cited rule to provide alternative notice compliance for companies providing a money-back guarantee. To date DSA has not received a response to either our advisory opinion request or to our petition to amend the rule.
Since the rule is in effect, the need for Commission response immediate. DSA therefore requests that the Commission inform us as to when we may expect to receive the advisory opinion requested and the reaction of the Commission to our petition to amend the rule.
Very truly yours
Isl ;\eil H. Offen
Vice President and Legal Counsel