Telemarketing Rulemaking-Comment FTC File #R41101

March 28, 2002 Office of the Secretary Federal Trade Commission Room 159 600 Pennsylvania Avenue, NW Washington, D.C. 20580 Re: Telemarketing Rulemaking -Comment. FTC File No. R41101 Ladies and Gentlemen: This letter is in response to the Commission’s request for public comments regarding its review of the Telemarketing Sales Rule (“TSR”) as published in the Federal Register on January 30, 2002. The American Resort Development Association (“ARDA”) is the Washington, D.C. based trade association representing the vacation ownership industry. Established in 1969, ARDA today has over 800 members, ranging from small, privately held firms to publicly traded companies and international corporations. ARDA’s diverse membership includes companies with vacation timeshare resorts, private residence clubs, land development, lots sales, second homes and resort communities. However, the majority of ARDA’s membership is related to the timeshare industry ARDA submitted comments during the first round of review, pursuant to the Notice 1issued February 28, 2000. ARDA appreciates the Commission’s references to those comments in the most recent Notice and hopes that our input has been helpful. These comments supplement our prior submission, which may also provide relevant background information and help clarify our position on pertinent issues if questions arise in connection with this submission. ARDA appreciates the opportunity to ...