Comment Number: 522418-03634
Received: 6/21/2006 2:25:10 PM
Organization:
Commenter: Phyllis Hebert
State: MO
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
Attachment: 522418-03634.pdf Download Adobe Reader

Comments:

Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it would prevent the business I operate from continuing as a XanGo [TM] Independent Distributor, and would destroy the small business I have worked so hard to build, as well as those of thousands of others. I have been operating a home based business, which is an Independent Distributor representing XanGo LLC, for just over one year. I contracted to operate this business because I love the product, I believe in it and want to share it with others. I am retired. I now operate my XanGo business full-time to supplement my income to support myself and my disabled companion. There are thousands who are solely supporting their entire family from their XanGo income. Please don’t destroy my small business, we need it! Some of the sections in the proposed Rule 511993 would make it hard or almost impossible for me to sell the XanGo product and would make it especially difficult to introduce others to this fantastic opportunity. Changing to the new rules would devastate the growth and profit potential of the business I operate. This seven-day waiting period will give the public the idea that there is something wrong with me or our XanGo business plan and also reflects badly on me. I also think this waiting period is unnecessary, because XanGo already has a 90% buyback policy for all products including sales kits purchased by a salesperson. One of the most difficult sections of the proposed rule is the seven-day waiting period to enroll a distributor. The procedures associated with this proposed rule change would make it extremely difficult to build a XanGo business, because it would stifle the initial profit making it less profitable than it currently is under the existing rules. For a new rule to stifle profit should point out the inadequacy of thought that generated this new rule proposal. The XanGo sales kit costs only $35. People buy TVs, cars, and other items that cost much more and they do not have to wait seven days. Under this waiting period requirement, I will need very detailed records when I first speak to a new prospect. Then I will have to send reports to my company. I am a small home business, this burden could destroy my business by requiring excessive paperwork. A person would have to be a superstar instead of just an ordinary person seeking to get ahead. With these new rules, the XanGo opportunity would cease to be for the average person, it would require one to be an aggressive and capable business person in the beginning. Finally, the proposed rule requires the disclosure of a minimum of ten prior purchasers nearest to the new prospect. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving personal information of individuals (without their approval) to strangers. Women in my organization my 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 to monitor actions related to the disclosure forms. I have seen many scams on the Internet. They hurt my business! This rule will not stop Crooks – they violate the current rule all the time. Go after those who currently take advantage of others daily, who are damaging or hurting innocent people. But I am a good American citizen and Rule 511993 will hurt me! Thank you, and please help me retain the right to operate my business where the company, XanGo LLC already has procedures in place to protect anyone from loss of money and/or time and credibility. Sincerely, Phyllis L. Hebert