|Received:||6/19/2006 11:57:56 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Hello, and thank you for the opportunity to express my views on the Proposed FTC Business Opportunity Rule. What a great country we live in! First off, I would like to express my sincere gratitude toward the FTC and those whom are serving to protect my best interest as a consumer and business owner. Your role is vital to our freedoms and pursuit of the American Dream. However, it is my belief that the proposed Business Opportunity Rule will actually do more to limit my freedoms and pursuit than it will to protect and foster them. I have been in direct sales and marketing through the network marketing venue for almost 10 years now. I have made from $300/year to $13,000/year and everywhere in between. And that suits me just fine. I chose multi-level marketing (MLM) venue due to its flexibility of part-time schedule and income and because of the vast educational and personal growth opportunities it offers. I do not make a living at it – it is not my intention to. What it offers me is vacation, Christmas, birthday moneys and it has done that quite well. Furthermore, the education and personal growth training I have received, I have been able to apply toward my career and prosper there as well. My concerns regarding the proposed Business Opportunity Rule and how I interpret its impact on my business is as follows: 1) The seven-day waiting period is impractical in the light of any sales of any industry that I have ever been a part of. I don’t have to wait seven days to buy a car, a boat, a computer, a large screen TV, a pizza or anything else that I can think of. I don’t have to wait seven days to buy office equipment, construction materials or any other equipment – even if it is my intention to turn it into a business. I don’t have to wait seven days to become an independent contractor for any industry that I can think of. Furthermore, that last 100 years of sales training literature will have to be re-written. 2) Elimination of the $500 business threshold would also limit the attractiveness of this type of industry. I personally chose MLM because of its low entry costs and that is an attractive feature to many of the new recruits that come on board with me. This is part-time work for us and we like that. 3) Reporting of a 10 year litigation history of the company regardless as to whether it applies to me or not is overly burdensome to me as the individual and raises a red flag to any potential client. In almost ten years in this industry – no one has ever asked me for this information. 4) Providing data on my earnings is a violation of my personal right to privacy and won’t stop those who are already being dishonest. If they are willing to lie to get a sale, they will be willing to fabricate any kind of earnings history. 5) Providing the references of the 10 nearest existing sales people is also impractical. The whole idea of MLM is to market to your spheres of influence. Two neighbors most likely know completely different people and there paths may never cross. To bring this topic to the table would only bring questions that someone who does not understand the beauty of the network marketing system could interpret negatively. In almost ten years in this industry – the topic has never even come up with the people I have talked to. In summary, I believe the proposed Business Opportunity Rule does more to limit my freedoms as a business owner then it does to protect the consumer from unscrupulous sales people. Tying the hands of the honest does not stop the dishonest. Adding more paperwork, disclosures and bookkeeping to me and my upline and my downline only passes greater expense on to the consumer and does little to protect them from the dishonest people. Thank you.