|Received:||7/2/2006 12:09:31 PM|
|Organization:||Business Research Associates|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
|Attachment:||522418-05598.pdf Download Adobe Reader|
Comments:re: NEW F.T.C. RULE for "Biz Opps" We support the idea of having MLM-type "Business Opportunities" --any enterprise that claims to offer people a program or plan to increase their wealth via Network marketing, building a downline, or similar. We think that not only should these businesses REGISTER with the FTC, there should be an IMPROVED way to COMPLAIN and investigate violations. These Disclosures should be provided by the OWNERS (CEO, founders and staff) of the Business --- not by each and every common distributor. 1. THIS RULE SHOULD INCLUDE all MLM-- or "Biz Opp"--- multi-level marketing companies--any promoter who advertises --- "financial freedom via selling their deal"--- must comply with earnings-claims disclosure rules. No multi-level marketing company should be given an option of making "no earnings claims". 2. Multi-level marketing companies must disclose STATISTICS....e.g.-- the average retail-based income earned by participants in each level of the hierarchy. 3. Income disclosures of multi-level marketing companies must include: -- The total number of all participants who joined in the past year, not just the so-called "active participants" in one part of a year. -- The average NET, not gross, income of participants in each level. Expenditures paid to the company include product purchases, renewal fees, shipping costs, books, audio and video tapes, training and motivation seminars, computer fees, etc. REQUIRE: REGISTER & DISCLOSE COMPLAINTS only if they are-- "Cease & Desist" Letters from Attorney Generals or similar agencies; COURT ORDERED Judgements against the company for Business Fraud, Deception, and similar. It is not necessary to know of any other unrelated litigation or complaints. And--- it is not necessary to disclose the names and address or any personal expenditures of customers, distributors, etc. It is much more important and essential for inhibiting FRAUD to have the owners DISCLOSE their legal structure, owners, addresses & phone numbers, any other contact info on the owners, what they are doing, who they are helping, costs, and legal judgements against them for FRAUD. Most of all, as consumers, we fully support an improved COMPLAINT PROCESS that expedites investigations against those who are cheating, deceiving and operating illegal PYRAMID SCAMS.