| Comment Number: | 522418-02286 |
| Received: | 6/15/2006 10:33:19 AM |
| Organization: | |
| Commenter: | Tom OBrien |
| State: | Not in the US |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Whilst I agree with the sentiment of this new rule, unfortunately in it's current guise it is unworkable and onerous on any business operating an online presence. We all want to get rid of bogus merchants on and offline but this is not the vehicle to do so. For example, the provision to display references contravenes the Data Protection Act here in the UK and I'm very sure speaking as a consumer I would not want my details distributed to anyone who called for a reference from a business. Disclosure of sales information is a violation of business privacy and opens up too much information for competitor analysis - this would only result in dominant players reaching unassailable dominant positions more quickly than ever before. Updates to purchasers on a monthly basis of any changes to the form disclosed by the seller will only result in purchasers receiving extra unwanted mail (particularly if there is any form of volatility in the form due to legislative changes). Disclosure to prospects 7 days prior to the consumation of a deal is of course unworkable for real time transactions. Any such information can/should be furnished at the point of sale. Regards, Tom