| Comment Number: | 522418-02569 |
| Received: | 6/16/2006 10:16:43 AM |
| Organization: | National Lending Corporation |
| Commenter: | Jonaku MetuAssalol |
| State: | TN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: I am writing in reference to the proposed Business Opportunity Rule R511993. I believe that in its current form, this rule could prevent me from continuing as a National Lending Corporation consultant. I understand that part of the FTC's responsibilities is to protect the public from "unfair and deceptive acts or practices." However, some parts or sections in the proposed rule will make it extremely difficult, if not impossible to market and sell National Lending Corp. products. I have been in the Direct Sales and Network Marketing business for over 20yrs. It has allowed me to send two daughters to college and receive their degrees. It will allow me send a third child to college in the fall of 2007 (my son). It has by far, been such a rewarding career that has allowed my family to achieve the "American Dream", e.g. home ownership, college education, travel, and the love of our country(USA) and family. My family is totally dependent on the stability of the Direct Selling and Network Marketing industry. I unequivocally love America and the Direct Selling and the Network Marketing industry!!!!!! The challenge lies in the cumbersome and burdesome sections of the proposed rule that require implementation of the seven-day waiting period to enroll new consultants, distributors, representatives, associates, etc. in our business. Americans consumers purchase all types of items without having a seven day waiting period. There currently exists "72 hours" disclosure and "truth in lending" and "good faith estimates" and we (National Lending Corp.) are fully governed by accredited authorities. The waiting period that is proposed gives the impression that there is something wrong with our company or its compensation plan or products. In addition, the proposed rule calls for release of any information regarding lawsuits involving misrepresentation, or unfair, or deceptive practices. It does not seem to matter if the Company has been found innocent of any wrongdoings. Unfortunately, we live in a highly adversarial and litigious society. However, the tenet as you well know that is so profound, is "presumed innocent until proven guilty". Thus, we steadfastly maintain our innocence and the intergity of our industry and business. Please do not cast out or punish the innocent majority of Direct Sellers for the misdeeds of the few or minority. Finally, the proposal to disclose a minimum of 10 prior purchasers nearest to the prospective purchaser puts us (Direct Sellers) at a competive disadvantage. Furthermore, with concern for privacy rights, and identity theft, this proposal could lead to further litigation against our industry. Customers would be reluctant to share that information with total strangers. In summation, I appreciate the work the FTC does to protect the American consumers, nevertheless, I think this proposed new rule has many negative, detrimental, however, unintended consequences. I believe there are less burdensome and cumbersome alternatives to achieving the goals of the FTC. I thank you for your time in considering my comments. Respectfully, Jonaku MetuAssalol