| Comment Number: | 522418-03843 |
| Received: | 6/22/2006 2:56:23 PM |
| Organization: | Vemma |
| Commenter: | Diana Davis |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
The list of nearest references for each local member/distributor would not deter fraud, but would incur a hardship on the local distributor to comply. The seven day waiting period is excessive considering one only has three days to change thier mind about refinancing a home mortgage, which is many times more expensive than most of the current business opportunities offered for under $500. A three day waiting period is not out of line. Legal actions requirements should not include any other businesses one is involved in, since my mortgage business has nothing to do with my Vemma business and should have no bearing on any Vemma sales or opportunities. The cancellation requirement should include the reason why cancellation was done, to protect the business. Not all cancellations are because of negative problems, and without the reason for cancellation, it sends a unfair negative signal which is unfair to those companies who operate with integrity and good business practices. When I was looking for business opportunities, I ran into many unscrupulous practrices and lost several thousand dollars until I found a couple of opportunities I felt were right for me with companies that were operating legally and with integrity. The things I noticed that could be regulated to help cut fraud would be the following: The bate and switch routine used to get a person's money then whent he "rest of the opportunity story" is revealed, they want more money for the "best program", more money for the "best" training, or more money for the "best" marketing program, etc. FULL DISCLOSURE FOR THE OPPORTUNITY OFFERED would be "best" for the client and is more easily regulated, controlled and punishable if not complied within the regulations. Then customers would know if the opportunity offered changed after getting the first payment for services or product, they would have recourse, which we do not have when fraud occurs now. Thank you for your time