Requester Records - Periodicals
REVISED August 2012
This Customer Support Ruling
discusses valid requests and the types of records publishers should
maintain to support compliance with circulation standards for
Domestic Mail Manual (DMM) 707.6.4.2a 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
Generally, the types of records
specified in DMM 707.8.1.4 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
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.
A request that expresses a desire
to receive copies of future issues of the publication transmited
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.
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.
Requests induced by a premium offer
or by receipt of material consideration are not valid.
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 rate or that may have been induced by a premium
offer or by receipt of material consideration.
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.
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.
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.
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.
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
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
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 707.8.2) are
acceptable. Presently, the following independent audit bureaus are
authorized by the USPS: 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.
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
United States Postal Service
Washington DC 20260-5015