| Comment Number: | 522418-03597 |
| Received: | 6/21/2006 9:37:55 AM |
| Organization: | Xango |
| Commenter: | Sue Carroll |
| State: | TN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I'm writing in reference to the Business Opportunity Rule R511993. I am an Independent Disbributor for XanGo. I have worked my network business for 17 months. I started my business because of the positive results I personally saw from the product. My husband and I needed additional income. I found that I could work my small business part-time nights and week-ends and still continue my full-time job. The added income has helped my family to be able to better meet our financial responsibilities. I have gained confidence in public speaking as well as presentation skills. I have helped others start their busineses which has helped them financially. It has given me the opportunity to give to others that I was not able to do before my business. I appreciate the FTC's priorities to protect the consumers. I am concerned of the impact the Business Opportunity Rule R511993 will have on direct selling companies. I understand fraudulent groups are out there that just want to ripe off consumers. However I do believe that this particular rule unfairly targets legitimate direct selling businesses. I believe a 7-day waiting period casts a negative light on my business. As a consumer I would question why a company has to follow such a rule. The record keeping and administration difficulties would be huge. There would be unnecessary delays. Since I can work in 14 different countries this would be impractical and difficult for me to comply with such a rule. To eliminate the $500.00 Business Threshold forces me in my small direct selling business to comply with other provisions of the proposed rule that are more appropriate for businesses requiring a much greater investment than a direct selling sales kit. One reason that I choose my direct sales business was that I ddn't have the funds to start a business with a large investment. To have to report all litigation without regard to winning or losing of lawsuits is unfair to all businesses. Today anyone can sue anyone or any business even without just cause. To me it puts a negative impact on the business even if they win all of the litigations. In the Business Opportunity Rule R511993 in would be difficult to collect the required data for earning claims. Fraudulent groups would not provide accurate data whlle legitimate companies would. While attempting to affect the fraudulent businesses I believe it would negatively affect the legitimate businesses. The impracticality of finding the 10 Nearest References of existing sales people in my business is enormous. The privacy and safety issues are too many to list. There would be possible corporate liability for ID theft. ID theft is a liability we all need to be watchful of today. Information is already too available to others. I respectfully request that you consider my comments and my desire to be able to continue to work my legitimate direct sales business. Sue Carroll