| Comment Number: | 522418-04875 |
| Received: | 6/28/2006 5:00:20 PM |
| Organization: | Image Development Group, Inc./Arbonne International |
| Commenter: | Debra Fox |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing to express my concern with the new Business Opportuity rules/laws that are being considered. I am an Independent Consultant - Exec. Regional Vice President with Arbonne International, a network marketing company that I've been with for 10 years. While I completely understand the need for concern as it relates to protecting consumers, I believe that some of the proposed rule changes are out of line and unnecessary. Specifically, asking independent consultants to provide a disclosure about a proposed company (in my case, Arbonne). I feel this is the responsiblity of the individual companies to provide necessary information on their websites so that people considering the business opportunity can access the information as they deem necessary. In ALL other businesses, there is a wide acceptance of the "buyer beware" practice --- why should independent consultants be required to provide information to each prospect when other industries/companies are not required to provide the same when they sell me something? I say, make it available, tell them where it is and let them be responsible for checking it out! If you wish to pass laws/rules, then pass a rule that the start-up costs for network marketing companies can not exceed $2,000 --- we all know that it does not take thousands of dollar to start a networking business -- but some supplies and demostrators are necessary. The reason we have so many problems with direct selling companies, is because there are always a "few" distributors who abuse the system by charging people $2,500 -- $10,000 in product to start. That should be against the law as it leaves a bad taste for everyone who is burned by it!!! The direct selling industry (Arbonne International specifically) SAVED MY FINANCIAL LIFE and I hate to see proposed rules affect the ability for individuals like myself to recover from financial devestation. This is one of the few ways that a single 40+ year old woman with no college degree can make a financial difference. I represent several minority groups and I would like my voice to be heard! Network marketing/direct selling is a viable business opportunity. As with EVERY THING ELSE, it is the individuals who abuse the systems that create havoc. Go after them specifically and let the rest of us operate ethical businesses. Debra Fox