| Comment Number: | 522418-04446 |
| Received: | 6/26/2006 10:33:35 PM |
| Organization: | MDB ENTERPRISES UNLTD. |
| Commenter: | Mel Banfield |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Mel Banfield MDB ENTERPRISES UNLTD. 6779 Deer Bluff Dr. Huber Heights, OH.45424 Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) Re: Business Opportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 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 could prevent me from continuing as a Xango Distributor.I have been an independent Distributor for more than 2 years. Originally, I started my Network Marketing because of the products I loved them and wanted to earn some additional money. Now my family depends on this extra income to supplement our budget. Please don’t destroy my small business we need it! I have been in Network Marketing for over 10 years, I believe it to be the best way a person can make a living and build a passive residule income for such a small investment.Your rule will hurt the honest worker and will not stop the crooks. I will shoot you some bullet statements on that later in this letter. Some of the sections in the proposed rule would make it hard or almost impossible for me to sell my Xango. 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. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new Distributor . Xango sales kit only costs $35.00. People buy TVs, cars, and other items that cost much more than that and they don’t have to wait seven-days. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone a prospect and will then have to send in reports to my company. I am a small home business and this burden could destroy my business. 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. In the end the rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. I have seen many scams on the Internet and been approached by many crooks because of my success. This rule will do nothing to stop them. They hurt my business! This rule will not stop Crooks – they violate the current rule all the time. But I am a good American citizen who served this USA in Wartime 1965 thru 1969 and it will hurt me. Thank you and please help me. $Dollars to sign up = Disclosure Crooks that currently violate the rule which is at $500 will not be hampered by $0 dollar limit. How the FTC justify more paper pushers to catch the crooks! Disclosure Form itself Will generate tons of paper that legitimate small home businesses will have to deal with. Environmental issues of just all the trees killed during global warming In a period of large Federal deficits it will add more "paper pushers" in Washington. Disclosure form signing then a Seven-Day Waiting Period -Casts MLM in a negative light which is unfair -Record keeping and administrative problems for your small business -Causes unnecessary delays for good people Litigation Reporting - Does not distinguish between Civil and Criminal cases to general public -Unfair that it does not distinguish between winning and losing lawsuits Requirement for 10 References in an area. - Can be used as a deceitful tool by Scam Artists -Impractical there may not be 10 people in a small town or county -Privacy issues due to ID theft and safety does the FTC plan to set up a liability fund to reimburse harmed distributors. May are women and this could make them vulnerable to rape and other crimes of passion The FTC’s Goals are noble, But There are millions of good prospects in the U.S. but how about more enforcement of laws on the books to stop Crooks from stealing them from good hardworking MLM Distributors? - The FTC’s proposed rule would unfairly target legitimate direct selling businesses. God Bless you for taking the time to save our industry. Sincerely, Thanks for your time and attention, Mel Banfield 6779 Deer Bluff Dr. Huber Heights, OH. 45424 www.melbanfield.com admin@melbanfield.com