| Comment Number: | 522418-03200 |
| Received: | 6/18/2006 1:14:55 AM |
| Organization: | Xango Distributor |
| Commenter: | Johanna Baker |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-03200.pdf Download Adobe Reader |
Comments:
Allow me to tell my story. I have been in Network Marketing for 13 years. I have been with Great companies. This last company Xango that I have been associated with is the BEST experience I have ever had. What I have loved about being in Xango is that the product has changed my life physically and the income that I am receiving is changing the future for my family. This company has a strong leadership with 6 very astute business men who have brought a category creating product to the market place. I am disabled with MS and can not work out in the work force. Xango and Network Marketing has created a place for me to not only help others succeed with their health but also with their financial lives. Where could a disabled person create a NEW future for her family? My husband worked for 10 years in County Government as the County Geologist but only half time. That means half retirement. Where and how could we build a retirement income for ourselves with me not even being able to work. I have been incredible grateful to have an industry and a company that has such high standards for our conduct and such an exemplary product that has not only changed our lives but is giving me the opportunity to help others instead of being a person that only has to be on the receiving end of help. I understand the FTC’s role in protecting today’s consumer. However, even the best of intentions can result in negative outcomes. In my personal opinion the FTC is perilously on the edge of just this type of situation. Direct selling and network marketing comprise a sizeable portion of the U.S. economy. We can all argue percentages, but have to agree on the fact we’re not talking about a minor smidgeon. Placing regulations and legislation in motion that will impede legitimate commerce will only damage the U.S. economy. Some of the sections in the proposed rule would make it hard or almost impossible for me to sell my Xango products. This waiting period will give the public the idea that there’s something wrong with me or our plan and also reflects badly on me. I also think this seven-day waiting period is unnecessary, because Xango already has a 90% buyback policy for all products including sales kits purchased by a salesperson. On another point in the proposed rule, providing litigation data, with no observable reference benchmark nor clarification of the data is purely misleading. Can I find this same data on Microsoft? Is there any “national standard” information to help me evaluate Microsoft? Compare it to the industry or nation? Providing law suit information, can you tell me, from that fact alone, will give you the information that tells you about my company since being in business? There is a serious flaw in the logic of this rule. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Women in my organization may be subject to sexual or racial harassment so this part can’t go in at all, unless the FTC passes an addition to this rule, prohibiting sexual or racial attacks related to this disclosure. You are creating a free method for unscrupulous direct sales people to get ten free leads from each new person they contact. You will also cause ten distributors to now be recruited by another company. Also, this rule will encumber the individual companies, with the responsibility of providing this data for hundreds of thousands of people trying to earn a living. This portion of the rule will remove spontaneity and energy from the business. You’ll kill business momentum. What I’m sure you are about to find out is how many people you are touching and how we can respond. Listen carefully to the feedback you’ll get.