Tongues were wagging at DMA07 in October, following Direct Marketing Association (DMA) President and CEO John A. Greco, Jr.’s announcement of the organization’s new Commitment to Consumer Choice (CCC) program. The program also could be referred to as “Consumers Compel Competition.” After all, steps that restrict a company’s ability to communicate marketing offers directly to consumers pretty much require that company to up its game on other levels to avoid a falloff in revenues. But as the DMA knows, marketers don’t have much of an alternative.
Fifteen states proposed state do-not-mail registries or other limitations on direct mail in 2007, a 375 percent increase over 2006. We’ve been laboring under a false sense of security on this issue because of the USPS’ dependency on advertising mail to operate; one-third of its annual revenue comes from direct mail. Certainly, the USPS can function with reduced ad mail volume, but it means the cost for every other user of the mail system goes up. Do most consumers understand this? Let’s say they do and still prefer, for environmental and personal concerns, to pay more for their stamps to reduce the amount of direct mail they get. It’s a possible and reasonable option in a free society.
It also means the complexities of developing a system that addresses the numerous issues related to enabling consumers to control the amount, type and timing of direct mail they receive are the cost of doing business in this channel.
Back to the CCC program, which requires marketers to provide opt-out notices or contact modification details in customer acquisition and retention mailings; honor opt-out requests in a timely fashion; use DMA’s Mail Preference Service (MPS) suppression file; and disclose to consumers, on request, how their personally identifiable information was obtained. Penalties range from censure to suspension or expulsion from the association.
Without question, these are best practices every marketer should follow; what is dubious is whether DMA members will comply. Do they really believe the DMA will kick them out? If it does, consider the financial implications of paying nonmember rates for conference registrations, reports and other products/services the organization offers; most conference fees cost $500 more and reports cost from $50 to $300 more. That seems like small potatoes compared to the costs of a rigorous in-house suppression program. But how about in comparison to the costs of lobbying Capitol Hill and state legislatures? Or the enactment of a patchwork of state do-not-mail laws, followed by a federal law? (I do believe some sort of government mandate is forthcoming.)
Obviously, you can choose to ignore the indicators that consumer-driven government regulation is nipping at our heels. But if you heed the DMA’s call to action, you will be protecting far more than your current or future membership status. You’ll be in a more competitive position, hopefully enjoying a better relationship with your customers, when the laws go into effect.