| Comment Number: | 522418-01427 |
| Received: | 6/8/2006 1:34:48 PM |
| Organization: | Primerica Financial Services |
| Commenter: | Warren Pace |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am concerned about the proposed New Business Opportunity Rule R511993. I am afraid that in its present form, it could severely hurt my business as an Independent, Licensed Agent for Primerica Financial Services, I understand that part of the FTC's responsibilities is to protect the public from "unfair and deceptive acts or practices," but some of the sections in the proposed rule will make it very difficult if not impossible for myself and my company to continue doing business. Our company serves "Middle America" with Debt-Reduction Counseling and Services, Term Life Insurance provided by an A++ rated company and we do primarily conduct our business by referral and word of mouth advertising. We are a wholly-owned subsidiary of CitiGroup and a highly respeced company. We do recruit as part of our business activity when we find high quality individuals that are willing to attend a state Licensing School and get their state license. We conduct our business in a professional, honest and above board manner. The proposed "reporting" that is suggested in Rule R511993 is much too "far reaching" and would be a burden that would severly affect our ability to serve our clients. It also would require divulging "private, personal information" that would certainly not be appropriate or respectful to our present clients. I believe this proposed new rule has many unintended consequences, which may destroy my business. We also believe that there are less burdensome alternatives available in achieving the consumer protection goals stated in the proposed rule. Thank You for your time in considering my concerns. Sincerely, Warren Pace