Legal Matters: Beneath Those Refund and Return Policies

… has a policy of not making refunds, cancellations, exchanges, or repurchases … ; or, if the seller or telemarketer makes a representation about a refund, cancellation, exchange, or repurchase policy, a statement of all material terms and conditions of such policy.

The Telemarketing Sales Rule provides, however, that telephone calls placed by customers in response to direct mail solicitations are exempt from the Rule’s requirements if, among other things, the offerer’s refund policy is clearly disclosed for customers in the initial solicitation.