| Comment Number: | 522418-03148 |
| Received: | 6/17/2006 5:18:22 PM |
| Organization: | Roberts Associates |
| Commenter: | James Roberts |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing regards the business opportunity rule,R511993. I operate my business as an individual and do not have access to all of the proposed information required under the new rule. For example:1.) the product I sell has very important life saving properties and in many cases waiting even seven days might make the difference between life and death. My customers need to take action immediately.2.) I could not find the ten nearest existing sales people.3.) I also have no way to find what people are earning doing this business and Xango doesn't make any earnings claims. I think that their approach of making no earnings claims should be the model for direct sales companies. They do provide information which you could use to calculate what you might make, but they do not quote numbers.4) The litigation requirement might be useful if it required reporting of lawsuits lost. The idea of reporting all lawsuits can be misleading. As you know their are a lot of frivolous lawsuits out there. 5) The $500 business threshold is a good idea and should remain. The small businesses that operate under this number are not going to interest the big scam operators. I think the whole concept of protecting people from fraudulent businesses is great, but this law as proposed is putting an unnecessary burden on the small operator. The things you see on TV where you can make millions following someones plan should require some backup. I am retired without any income other than social security and working with Xango offers an opportunity to supplement that income and help people with health problems at the same time. It is very helpful and I hope that you can construct a way of protecting the public without the provisions proposed that would make it difficult for the small operator to continue. James Roberts