Comment Number: 522418-05403
Received: 6/30/2006 11:39:12 PM
Organization: Vemma
Commenter: Beryle Skaar
State: WI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

This mail is in reference to the proposed "Business Opportunity Rule, R511993". I see more proposals that stop legitimate business while having very little effect on fraudulent business. The $500 Minimum Business Investment Requirement forfeits many individuals right to engage in business when it is not necessary for the investment. The Seven Day Waiting Period will put an unnecessary inconvenience on people interested in joining a legitimate business and only create a risk that is not necessary for me. The List of Nearest References will only make an overload for myself and the company and extend the Seven Day Waiting Period, completely unnecessary. This list goes against every privacy and confidentiality ruling ever put into effect. The Earnings Claim Statement does nothing to deter fraud at all, this is what they're good at, it only puts more unnecessary requirements on me and my company. The Legal Actions rule could disclose litigation that has nothing to do with the business opportunity (more privacy issues) and does not provide for the disclosure of the outcome of the litigation. The Cancellations and Refund proposed ruling punishes the company that has a very liberal cancellation and refund policy. This proposed rule will require thousands of individuals to keep unnecessary records of all oral and written requests for cancellations and refunds. The new proposal also states that there would be rules that would prohibit unfair or deceptive practices that are common among fraudulent business opportunity sellers. There are already laws in effect for these practices. The new business proposal would wipe out a whole legitimate industry. I hope this is not your intention. I am associated with a company that I believe operates with an honesty almost unseen in the country, of which I am grateful, this proposal will put a devastating negative impact on that. It is clear that the proposed "Business Opportunity Rule, R511993" puts more unnecessary requirements on the legitimate business than it would put on the fraudulent business. It is obvious this proposal has other interests in mind. I thank you for your time.