|Received:||6/17/2006 8:25:34 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am concerned about the proposed Business Opportunity Rule and its negative implications on my home business. While I appreciate the concern to deter fraudulent practices, some proposals would just allow fraudulent individuals to continue their practice, while throwing roadblocks in the path of a legitimate direct sales business. The seven day waiting period is unnecessary. A legitimate company offers a satisfaction guaranteed policy which includes 100% return on cost of product if unsatisfied. A seven day waiting period could just throw unnecessary suspicion into an otherwise enthusiastic customer's desire to try the product and block a sale. Also, disclosing a specific number of cancellations and refunds would not accurately reflect the business to a consumer, as many distributors may cancel for reasons totally unrelated to the product or the legitimacy of the business. Litigation reporting will not produce the results that the FTC is looking for because it doesn't allow for reporting of outcomes. In the healthcare industry physicians don't have litigation reported on the National Practitioner Data bank without outcomes posted as well to promote a balance picture, and the same should apply to the direct sales business. The earnings claims and list of nearest references puts undue burden on the individual distributor who often is pursuing this opportunity as a second income, and does not have the resources to pursue this information to the extent the ruling requires. It will not protect the consumer, as fraudulent individuals will just provide false information, while the legitimate business will spend valuable time and energy (at their own expense) to comply. Providing a list of the nearest existing sales people could also open these individuals up to identify theft. Thank you for listening to my concerns. I appreciate the FTCs mission for consumer protection and hope you consider my comments while evaluating the proposed Business Opportunity Rule.