| Comment Number: | 522418-02509 |
| Received: | 6/16/2006 12:25:05 AM |
| Organization: | Shared Results International |
| Commenter: | Linda Keefe |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To the FTC -- Ref: R511993, We appreciate the role the FTC plays in protecting consumers from misleading and fraudulent activity. We know that you work diligently to create laws and rules that are fair and effective. We also know that as such, you will listen with an open ear to those of us who are both consumers and legitimate business people. I own a consulting and training company which was founded 11 years ago. We have a fine reputation and recognizable clients. I also have two direct sales businesses - one with XanGo and the other with AdCalls. Both organizations have the highest ethics and practices. Individuals and businesses benefit from the products and services that are made available to them. There are several aspects of this proposed rule which will create an undue hardship for both the entrepreneur and the consumer -- counter to the intent of protecting the consumer. Surely we all want the fraudulent activity to cease and desist. We will have to be more creative in targeting these practices and eliminating them, rather than to just lower the bar placing restrictions on legitimate practices. For instance. 1) the Direct Sales industry has been building its image with the consumers; it has become a very viable way for business to be conducted. The 7 day rule will cast a shadow of unrespectablility that will make it difficult for us to overcome. 2) Purchasing materials and a kit to get started at a nominal rate is basic business 101. Surely removing the $500 threshhold will make going into business more prohibitive. Our country was founded and thrives on entreprenuerial thinking and acting. We must not rule ourselves into inaction. 3) I can't imagine reporting litigation without the results. Information provided in incomplete form is misleading. If the intent is to protect the consumer, we must respect them and give them all the information including the outcome of lawsuits. 4) We use references in our training business for large, thousand-dollar engagements. The idea of finding 10 references for a small start up enterprise places an undue stress on all individuals and seems out of proportion to the need. I strongly urge you to reconsider alternatives to this rule so that the consumers are adequately informed, that fraudulent activity is stopped and that legitiamte Direct Sales businesses are not indirectly strangled. This doesn't help our economy nor the consumers who want and need our products. Thank you for your consideration of these ideas. Linda Keefe, CEO