|Received:||6/30/2006 9:36:08 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I agree that a rule is appropriate to the direct sales/business opportunity industry however the rule as proposed goes beyond reasonableness. The rule should create a level playing field by requiring clear, simple, and standardized income disclosures that apply to all direct sellers. Each prospective business owner should be able to cancel within a reasonable timeframe shoud they change their mind. The proposed seven-day waiting period before a person could start their business amounts to over regulation and steals valuable time from them, potentially reducing a prospective business owner's income opportunity. The cancellation policy is sufficient protection. The requirement for references will disuade law abiding citizens from expanding their business. If a neighbor all of a sudden approached me with a fistfull of legal disclosures and financial records any opportunity being presented would no longer look achievable by me unless I was well versed in business law and finance. I would suspect them more if they did that than if they kept it simple and allowed me to learn as I started and built a small business. One of the tenants of the direct selling business opportunity is the ease of use. Complicating it with references and burdensome legal disclosures will steal the opportunity from more than it might protect. I don't need you that involved in my affairs nor do I need you to assume the job of the courts. Most consumers and small direct selling business owners do not have the background or resources to manage the financial record burden you are proposing. A rule is a good and necessary thing but keep it so a first time business person can not only join an establishied legitimate opportunity and work the direct selling opportunity as a small business person without having to leap into managing unweildly legal and financial records. Alow me to take some risk.