| Comment Number: | 522418-02489 |
| Received: | 6/15/2006 11:21:50 PM |
| Organization: | East Mountain Chamber of Commerce |
| Commenter: | Bill Walters |
| State: | NM |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: The East Mountain Chamber of Commerce includes businesses in and around the mountain communities of Tijeras and Cedar Crest, New Mexico. About six percent of our current membership includes individuals in the direct selling industry. Therefore, the Chamber is compelled to give you feedback on the proposed Business Opportunity Rule R511993. In it’s present form, the rule discourages business. Certainly the FTC must protect the public from “unfair and deceptive acts or practices,” but some of the sections in the proposed rule will create a real hardship for our Chamber members in the direct selling industry. The seven-day waiting period seems like an unnecessary delay for people wanting to start a business. People make much more expensive purchases of other types without waiting periods. The waiting period makes the direct selling industry look shady. Our Chamber members in the direct selling industry are among the most ethical, upright of businesspeople. It would be unfair to cast their businesses in a questionable light. (Besides, it seems that “Caveat emptor” has served well for decades.) Also, the waiting period could discourage a potential new business owner because the lag time may reduce enthusiasm. In addition, the portion of the proposed rule that requires the release of any information about lawsuits also may cast doubt on valid businesses. Of course, require disclosure of lawsuits that find a direct selling company guilty of misrepresentation or unfair, deceptive practices, but do not require that a company disclose litigation in which the company is found not guilty. The East Mountain Chamber of Commerce appreciates the FTC’s work in consumer protection. But please, also protect and support small businesses by reworking the proposed rule. Remember—when such rules negatively impact small businesses, they impact an area’s economy as well. Sincerely, East Mountain Chamber of Commerce