| Comment Number: | 522418-02372 |
| Received: | 6/15/2006 4:02:43 PM |
| Organization: | Forever Green Enviga Solutions |
| Commenter: | Merlyn Gaspar |
| State: | CT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam, I am deeply concerned about Business Opportunity Rule R511993. Though I understand your intentions are to protect and serve the public, I cannot support this proposed rule for several reasons. First, as a network marketer, I believe this ruling will be burdensome and have an adverse impact on our entire industry. As you know, over 15 million Americans have seen the benefits of direct marketing to their personal lives, and have signed on. Many are part-timers who need to supplement their income or wish to test their entrepreneurial wings. But based on a database of 300 leads I once purchased, I was struck by the fact that what motivated about 80% of small business ad respondents was their simple desire to spend more time with their families. Network marketing can afford them an opportunity to do just that, potentially strengthening the fabric of our society. At the same time, I believe that the added recordkeeping and paperwork demanded by Rule R511993 actually works against this goal by placing an undue administrative burden on those parents. As a part-timer who works for a non-profit organization, I cannot imagine myself doing any other type of business than direct sales. It affords me administrative, training and marketing support while keeping paperwork to a minimum. Since my husband is retired, it also gives me a hope of seeing our family restored to financial stability. I believe that I have found the right company and the right suite of products to accomplish this goal. I have a deep respect for both the company and products that I represent. With our economy suffering as it is, I strongly believe that network marketing is one industry that should not be touched. Rather, the freedoms the industry provides need to be protected because it is serving a crucial economic purpose at a crucial time in this country’s history. Many individuals have pulled themselves out of debt through utilizing this opportunity. They are ordinary people with ordinary incomes who happened to find that with a minimal investment they could change their lives and the lives of others. Please don’t judge our industry by those few that might be overzealous and exaggerate income earning potential, etc. I have been involved with two other network marketing companies prior to the company I now represent. I am in the wellness industry, and have found all of my current and past associates to be people who genuinely care about the wellness message and want others to experience the same financial and lifestyle benefits they have found in network marketing. However, it often takes 2-3 attempts to find the right mix of company culture, products and marketing approaches. When people fail, they often fail because they just have not found the right “mix” that fits their personality and skill set. If your intention is to restrain those few who engage in misconduct, my concern is that they are the ones that will not honor the proposed regulations, and those who do will be left to carry the regulatory burden. In summary, our industry is a good industry, and is meeting a real need in this country. Put in perspective, I would venture to guess that the number of complaints you have received pale in comparison to the number of direct marketers who have not taken the time to tell you just how much this industry has meant to them and their families. There is such a variety of internet scams these days, I truly value the work you are doing to capture those real criminals who would steal our credit cards, promise merchandise that doesn’t exist, etc. That said, I appeal to you to withdraw the proposed Business Opportunity Rule R511993. Thank you for your serious consideration.