Comment Number: 522418-05407
Received: 6/30/2006 11:55:20 PM
Organization: Independent Distributor of Xango
Commenter: Dale Beaver
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Ref Business Opportunity rule R511993 I feel many of the proposed rule changes will impact my business. 1. To require a 7 day waiting period on what most companies require as a minimal investment to get started in their company implies there is a great risk and the business is not legitimate. We don't require a 7 day wait period for a person to go out and buy a $4000. home entertainment center. Why should the government hinder legitimate business from doing business. 2. The providing of names, the addresses, and phone numbers of nearest 10 purchasers to any prospective purchaser really violates the privacy issues of those 10 purchasers. If this was required of all business transactions, it would bring the economy to a standstill. As a global company, which Xango is, closest purchaser really is impratical. 3. My understanding of the current rules about income claims is that you can't make any specific claims and I support that. Each individual will achieve their own income level by the effort and work that they do. I believe people should be allowed to express the life style that they have achieved and to say they have reached a certain level in their business model which then can be checked by the purchaser. 4. Requirement to disclose all legal actions in this lawsuit age is also irelevant. Having to disclose that you were found guilty of misrepresention, fraud, securities law violations, or unfair or deceptive practices I would agree with. If your company was guilty, then you would have to disclose. 5. The proposed rule to disclose all refunds and cancellations is just an administrative nightmare. I worked in retail for 35 years and handled many refunds and to say we should provide that information to our prospective customers really serves no purpose. What makes sense is that all companys should provide a refund of purchases meeting the requirements of that company. These requirements should be clear and not burdensome to the purchaser. Most companies already do this because they want to maintain an excellent rapport with their customers. I understand you are charged with protecting the public from fraud and illegimate businesses. I appreciate your effort to keep these businesses from the public, but I believe the above rule changes above if far more damaging to legitimate direct sales companies than the protection it provides the consumer. Thank you for taking in consideration my comments. Sincerely, Dale Beaver