Have any of you looked at the Michigan telephone solicitaion rules that took effect last year? Has anyone looked at the definition of "existing customer" and had a big problem with how it applies to bank customers? Also, do any of you who have mortgage affiliates make calls to customers of the bank to sell mortgage products and vice versa?

I have a feeling these rules don't come into play for most banks in the state, but there must be a few of you who make such calls. I would like to chat with anyone who is affected by this to compare interpretations. Please post or email me

Would you happen to know where I could view those rules?

The Michigan rule is in the Michigan Home Solicitation Sales and Consumer Protection Acts. PA 612 and 613. MCL 445.111

However, there are federal requirements also in the FCC rules 68 FR 44144 (7/25/03) and, if any phone calls are made across state lines, then the FTC rules also apply. 68 FR 45804 (1/29/03).

Bodman, Longley wrote an article last year analyzing all three. Send me a message if you need a copy.