| Comment Number: | 522418-06100 |
| Received: | 7/5/2006 1:03:58 PM |
| Organization: | Independent Xango Distributor |
| Commenter: | Gary Klein |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To: Whom it may concern With regards to Business Opportunity Rule, R511993 I must protest this proposal as it would cause great detriment to my ability to build a legitimate home based business. First of all, the proposed Seven Day Waiting Period would be devastating as the decision to pursue a legitimate home based business is often spontaneous and the desire will often fade overtime especially considering the negative influences of others in ones circle of influence. This would be tragic for the entire industry and hurt only the legitimate companies while those commiting fraud will most likely ignore it anyway. Secondly, to require a list of Nearest References would, in my opinion, violate current privacy laws. I would have to get written permission from every distributor and customer in the nation to provide this information on demand. Additionally, many of my prospective business partners come to me through the internet and therefore do not disclose where they are from. Thirdly, though I am not opposed to substantiating earnings claims with valid documentation, this will not deter those who commit fraud as a practice. Fourth, requiring me as an opportunity seller to disclose all legal actions, regardless of outcome is liken to deflating the balloon I just blew up before handing it to a child. I have no problem addressing current and past litigation with prospective partners, but only if they request it and only if it applies directly or indirectly to the business opportunity itself. Fifth, requiring me to disclose the number of purchasers of the business opportunity in the last two years along with the number of oral and written cancellations is entirely not representative of the actual satisfaction of the individuals as many who join have simply short term goals. Every individual joins or quits for different reasons. In summary, this proposal would do a great deal of damage to the growth and stability of the legitmate companies in our industry while doing nothing to deter fraudulent activity. Making rules for people who do not obey rules is at best a complete waste of time. Sincerely, Gary Klein