1) They are overbroad -- they do not just apply to "telemarketers" (who I would define as being companies making massive numbers of cold calls at random), but also to ANY business calling ANY residence for ANY reason.
2) To be in compliance, ANY business, no matter how small, that wishes to call ANY residential number ANYWHERE in the US must pay over SEVEN THOUSAND DOLLARS A YEAR for access to the Do-Not-Call registry, even if they only need to look up an occasional number now and then; free look-up access is provided only for five area codes, which is often not enough to cover an entire state, and sometimes not even an entire metro area.
The bottom line is that these regulations are NOT "anti-telemarketer" -- the telemarketing firms will consider $7K per year to be small change, and it will be a relatively simple programming change to incorporate the do-not-call registry into their already-computerized systems. What these regulations REALLY are is "ANTI-SMALL-BUSINESS" -- most of us who are in or run small, non-telemarketing businesses cannot possibly afford this $7K per year, nor can we afford an $11K penalty. Thus, if the FTC regulations were to stand, this would effectively limit just about ALL small businesses to calling ONLY residences within a five-zip-code area. I call that "restraint of trade" -- the exact opposite of what the FTC has been tasked to do.
I hate telemarketing calls as much as anyone else. But there's got to be a better way to do this.
Let's cut down the hyperbole a bit.
Additional area codes beyond the first five are only $25 apiece, up to a maximum of $7,735 (for the entire US).
Anyone that is marketing to the entire US can afford ~$7K. Those needing the list for an entire state will pay a few hundred bucks (excepting the more populous states).