Customer Support Ruling
Requester Records - Periodicals
UPDATED May 2015
This Customer Support Ruling discusses valid requests and the types of records publishers should maintain to support compliance with circulation standards for requester publications.
Domestic Mail Manual (DMM) 184.108.40.206a provides that a Periodicals requester publication must have a legitimate list of persons who have requested the publication and 50% or more of the copies must be distributed to persons making such requests.
Generally, the types of records specified in DMM 220.127.116.11 are acceptable in establishing a publisher's legitimate list of requesters. Following are examples of additional records the USPS may examine to determine if requests are valid:
1. Source documents showing the signature of the requester and the date of the request. If the signature is omitted, it will not be considered a valid request. Faxed (signed and dated) requests are acceptable.
2. A request that expresses a desire to receive copies of future issues of the publication transmitted to the publisher by email communication may be counted if the request includes: (1) the title of the publication, (2) the requester’s name, (3) terms – length of the subscription, (4) the requester’s physical address, (5) the requester’s email address, (6) the date of the request, and (7) a copy of the offer. When audits are performed, publishers must print out all documents associated with a request for the names selected. If multiple titles are offered they must be produced by a single publisher. If the title is printed in full on the subscription offer, abbreviations in requester records are acceptable.
3. Signed and dated change-of-address notices sent from publication recipients to publishers are valid as proof of a request for 3 years from the date of the communication.
4. Requests induced by a premium offer or by receipt of material consideration are not valid.
5. Subscriptions for copies of the publication that are paid or promised to be paid for are valid toward the 50% request requirement, including subscriptions paid at or below a nominal price or that may have been induced by a premium offer or by receipt of material consideration.
6. Forms that solicit requests for several publications published by the same or different publishers are valid, provided that the requester initials the appropriate box(es) to indicate what publication(s), by title, he or she wants to receive. Each publisher must maintain a copy of the source document for audit purposes.
7. Requests that are more than 3 years old are not considered valid requests. If the date is omitted, the USPS will consider the request valid for 3 years from the USPS cancellation date on a mailed request or from the date the publisher’s records show the request was received.
8. Mailed copies addressed using an alternative address format are not considered requested copies; persons are not considered to have requested the publication if their copies are addressed in that manner.
9. Signed and dated requests for a quantity of copies (bulk requests) from employers that specify the employees, by name or position in the organization, who are to receive copies of the publication are considered valid requests. Other bulk requests for copies of a publication—for example, when membership organizations request distribution of the publication to all of their members—generally do not count as valid requests.
10. Forms used to obtain subscriptions sold in conjunction with the payment of membership dues or contributions are valid, as long as the forms are signed and dated by the requesters and show the amount apportioned for the subscription.
11. When a requester publication is issued by a nonprofit membership organization and distributed to its members—for example, when a garden club publishes a newsletter for its members—the organization may adopt a resolution amending the formative papers (e.g. bylaws or constitution) of the organization, specifying that each member will receive a copy of each issue of the publication. The resolution should be worded similarly to the following:
“Resolved: That a copy of [publication title] shall be sent to each member of [organization name].”
Records showing that the publication is distributed to members must be made available for USPS review and verification.
12. Audits of requester lists as part of a periodic verification of circulation of an authorized Periodicals publication when performed by authorized independent audit bureaus (approved under DMM 207.8.2) are acceptable. Presently, the following independent audit bureaus are authorized by the USPS: Alliance for Audited Media (AAM) (formerly Audit Bureau of Circulation,ABC); BPA International, Inc. (BPA); Certified Audit of Circulation (CAC); and Verified Audit Circulation (VAC). Only ABC and BPA may conduct verifications of circulation for an application for Periodicals mailing privileges or a reentry application changing the eligibility category from one to another, for example, from requester to general.
13. Requests obtained by telephone or Internet must have an auditable record that substantiates the request. At a minimum, records for telephone requests should include: (1) the name, address, and telephone number of the requester; (2) a copy of the text used by the interviewer that solicited the request; (3) the interviewer’s signature; and (4) the date of the interview when the request was obtained. This will provide the USPS with the minimum information necessary to contact the requester to confirm the request. For example, the USPS may use Form 3845 to be sent to the requester to confirm the request. Such confirmation is generally not necessary when telephone requests are substantiated by a business reply mail system or similar technique of obtaining the requester’s signature.
Lizbeth J. Dobbins
Headquarters, US Postal Service
Washington DC 20260-5015