|Received:||6/14/2006 1:22:58 PM|
|Organization:||Tracker Mo's Den|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:From what I understand of the proposed FTC New Business Opportunity Rule, it is clear to me that many, many legitimate, hard-working businesses and individuals will be negatively impacted by this decision, to the point of forcing the businesses to shut down and the individuals to be deprived of a viable income source. While I understand and appreciate the FTC's wish to eliminate fraudulant activity, this blanket solution will do vastly more HARM than GOOD. In a press release by mlmlegal.com (http://mlmlegal.com/FTC%20Business%20Opportunity%20Rule/FTCpressrelease.html),"The FTC has brought more than 200 enforcement actions against business opportunities using the Franchise Rule since it took effect in the 1970s." Now, while only the FTC can legitimize or correct this claim, that means that in approximate 30 years, they have had cause to bring action against 6.66 cases of fraud per year. Seven. Per year. Wow. Before the FTC makes any sweeping rulings about this action, they should consider the amount of people who are working online -- honest, legitimate, people who, for a wide range of reasons work online. Because the fact is, more than 99% of online business IS honest. I, for one, am a relative newcomer to online marketing. I began working last year when illness prevented me from continuing in my offline profession in the restaurant industry. I am a single mother of two and when I became ill (from chronic fatigue, ironically enough), and found myself without any visible means of support, I looked into working online. While I was going into it under the worst possible conditions (i.e., with little or no time or money to invest), I have still managed to keep my head above water and am just now beginning to see a positive income. If it weren't for working online, I would have had to go on welfare, simply because of my medical condition (which still plagues me). This ruling will probably shut me down. But I'm only one of many. I just sent an email to all my online colleagues. That is, people with whom I work with and do business with. In one short year, the list is over 132 other online marketers and business tool providers that I consider legitimate business people. Who are they? Some work at home after they were "out-sized" because they had the temerity to age past 40 years old or above and were replaced in their middle-management positions by fresh (and, gee-wiz, cheap!) college graduates; others work at home because they have small children or, in one particular case I know of, a special needs child. Now, there ARE scams. But most people with a little common sense see them as such right away. Basically, anyone who expects something for nothing will always be disappointed. This is eternal and no amount of laws will ever eliminate them completely. However, affiliate marketing and MLM systems are legitimate, VIABLE ways for people to earn a living. Affiliate marketing is very similar to a commission-based sales position. MLM (Multi-Level Marketing) systems are adjuncts to this. By definition, they must also offer an affiliate program (and product) in order to BE legitimate. And MLMs are very effective. Basically, if an affiliate brings in a new marketer, they receive compensation for that marketer's sales, i.e., another commission. The reason for this is so that EACH marketer can look to their sponsor -- a real person, not just a help desk in a corp. -- for guidance and support-- and each sponsor is motivated to provide that. As I said, there are some scams. And all marketers recognise that. But by lumping ALL MLM/Party programs under "franchises" this ruling would effectively eliminate the possibility of any one person to work online. For those who have no other recourse, society will end up paying for it with welfare and other programs. Lumping all MLM/Party programs into scams is the same as saying anyone who is in Washington is crooked.