CIPP/US Study Guide
Chapter 11: Telecommunications and Marketing

Prohibition on Unauthorized Billing and Pre-Acquired Account Information

The TSR bars billing without express, informed consent. Where the telemarketer already holds the consumer's account data (pre-acquired account information), strict rules apply - especially for free-to-pay conversion offers, which require the last four digits, express agreement, and an audio recording of the entire transaction.

The TSR strictly prohibits billing consumers without their express, informed consent. If the consumer gives billing data during the call, consent may be obtained in any nondeceptive manner.

If the telemarketer uses Pre-acquired account information for a Free-to-pay conversion offer, it must: obtain at least the last four digits of the account number; obtain the consumer's express agreement to be charged using that account; and make and maintain an audio recording of the entire telemarketing transaction.

For any other transaction using pre-acquired account information, the telemarketer must at minimum identify the account with enough specificity for the consumer to know which account will be charged and obtain express agreement to be charged.

Key terms - quick answers

What is “Pre-acquired account information”?
A consumer's billing account information that the telemarketer obtained from a source other than the consumer during the call.
What is “Free-to-pay conversion offer”?
An offer that starts with a free trial then converts to paid service when the trial ends.