
For whatever strange reason, the FTC is proposing to allow more sales to escape the rule by raising the threshold dollar value from $25 to $130.
This is dumb. Instead of weakening the rule, the FTC should strengthen consumer protection by making it clear that internet sales are covered by the rule. Here's the comment I submitted at the FTC comment site.
Rather than diminish the protections afforded by the cooling off rule, the FTC should instead make clear that all internet sales are presumptively governed by the rule, and require that sellers adhere to the rule for goods and services purchased over the internet except
(1) When the "goods" consist of software that is downloaded immediately upon conclusion of the purchase transaction; or
(2) when the buyer is informed, with a clear and conspicuous disclosure, that the cooling off period is limited to the lesser of three days or the period before seller delivers the goods to the delivery carrier for delivery to the consumer;
AND, if the seller does not transfer the goods to the carrier within the promised period, then the buyer may refuse the goods at delivery and receive a full refund of the total price paid, including delivery charges.