|Received:||7/5/2006 1:41:15 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I appreciate the work the FTC does to protect us as consumers and understand this can be a complex job to help the consumer and yet not hurt what makes the economy grow, small businesses and entrepreneurs. I do however have serious concerns about the proposed Business Opportunity Rule and the effect it will have on legitimate direct selling companies. I understand there are fraudulent groups out there that prey on naive consumers, but this particular rule I believe will unfairly target legitimate direct selling businesses. I left the corporate world almost 6 years ago to be able to work from home and spend more time with my family, but still contribute to the family income as most families cannot survive on one income, but two parents outside the home, make it very difficult to raise a family. This is an opportunity that many stay-at-home moms, single moms and dads, and family oriented people cherish. I ask that you examine closely how these changes will be detrimental to legitimate home-based, direct sales businesses. The Seven-day waiting period - Causes unnecessary delays in allowing someone to use our products, which also causes suspicions to rise for even legitimate businesses. These delays can also squelch the excitement of a new distributor and kill their momentum in getting their business off to a fast start. This delay will also cause record keeping and administrative problems, especially with the added rule of references, which could mean additional delays on top of that. References - Finding the 10 nearest existing sales people brings up some additional impracticalities. Since in our business we have a very low cost to start, everyone starts as a wholesale member, who can also become a distributor if he/she chooses to market the product. Some become casual distributors to cover the cost of their product usage. Therefore, it will be difficult to distinguish between sales people and product users and an expensive administrative burden on the home office of legitimate businesses. Illegitamate businesses will most likely just come up with any 10 names. This also brings up concerns for privacy and safety issues. All distributors will have to agree to have their names and contact information released to anyone inquiring about the business, which could include those shady businesses that the rule intends to control. Maintaining this information for public use can also lead to increased liability for identify theft. The rule in regards to earnings claims will also be difficult to collect the required data where legitimate businesses will go thru great efforts to comply, those targeted businesses will not provide accurate data. In light of the issues addressed, I ask that you consider the hindrance it will put on legitimate businesses while having little impact to those businesses you intend to target. Some responsibility needs to be with the consumer to do their homework and make informed decisions on their own, without the unnecessary expense being put on those trying to run a legitimate home business. Thank you for your time and consideration.