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Customer Support Ruling

   
 

Points Programs
Revised June 2014

PS-275 (243.2.2)

In this Customer Support Ruling, a case study clarifies whether certain “personal information” present in the mailpiece of a “points program” mailing is part of an “explicit” advertisement where all of the personal information is “directly related” to the advertisement and the “exclusive” purpose for including the personal information is in support of the advertisement.

This ruling concerns the classification of "frequent flyer" and similar points information as Standard Mail matter. In addition to the name and address of the customer (the addressee), the mailpiece date, and an identification number (none of which is generally considered to be “personal information” for mail classification purposes), the mailpiece sent by ABC Airlines contains fields that are completed by computer to show total mileage accumulated (including previous balances, miles earned, miles deducted, and current balance) and bonus member information (preferred miles, preferred segments, beginning and ending upgrade balances, along with deposits and debits to those balances) coupled with promotions on itineraries that could be used to attain additional bonus miles and membership points and encouragement to take advantage of those promotions.

Mailpieces containing personal information must be entered at First-Class Mail prices unless they are eligible for Standard Mail or Package Services prices under the provisions of the Domestic Mail Manual (DMM). DMM 243.2.2 provides that personal information may not be included in a Standard Mail mailpiece unless three conditions are met: the mailpiece contains explicit advertising for a product or service for sale or lease or an explicit solicitation for a donation; all of the personal information is directly related to the advertising or solicitation; and the exclusive reason for inclusion of all of the personal information is to support the advertising or solicitation in the mailpiece.

As an initial matter, review of the mailpiece indicates that it contains personal information; i.e., the information on mileage accumulated, flights taken by the addressee, and miles needed to attain a bonus award. Accordingly, in order to be eligible for entry as Standard Mail, the piece would need to meet the test established in DMM 243.2.2; i.e., contain explicit advertising for a product or service for sale or lease; relate the personal information to that advertising; and have no other purpose for inclusion of the personal information other than to support the advertising. This determination must be made on a case-by-case basis.

In this instance, the piece does contain explicit advertising for a product or service; i.e., explicit flights on ABC Airlines. Further, the personal information is related directly to this advertising; the piece states, in this specific advertisement, how double miles and additional points may be earned, by the addressee, to attain those miles towards redemption for tickets.

The final factor for consideration is whether there is any purpose for inclusion of the personal information other than support of the advertising. This is based upon review of the mailpiece, and if the piece indicates any other usage for the personal information, it does not qualify for Standard Mail prices. For instance, language indicating the information “should be kept for the member’s records” or can be used for “business planning” or “tax” purposes; directions to “verify” or “check” the information; or labels such as “Shares,” are examples indicating the presence of such other purposes. In the particular instance of the ABC mailing, no purpose for the presence of the personal information other than support of the advertising was revealed in the mailing, and was thus determined to be eligible for Standard Mail..


Sherry Suggs
Manager