| Comment Number: | 522418-06240 |
| Received: | 7/5/2006 7:09:58 PM |
| Organization: | VEMMA/ thelaststop |
| Commenter: | Martin Hens |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir/Madam, I am writing to you today with the express hope that you will take my comments re: "Business Opportunity Rule " to heart before rendering any decision. I have been around the direct sales industry for many years, waiting for a legitimate opportunity, and I believe that I have found one through VEMMA. It has lived up to all the expectations that I have had and will go as far as I can legitmately take it. I have quit my full time job in the hospitality industry as a manager to be able to choose the type of people that I work with and bring into business. I applaud the fact that you want to protect the public from schemes that have no legitimate product or service and are merely a pyramid or "PONZI" scheme. We are a legitimate business with a legitimate, high quality product. The rules changes that you are proposing would be an onerous burden on small business people in direct sales. I don't think that we need a seven-day waiting period, we are not trying to buy a firearm, we are trying to offer a quality business opportunity, and the ability to step away from rigors of a 9 to 5 job, be your own boss, and live the way that you want to. Our opportunity is very reasonable to get in, and like any business you have to spend some money to be successful. It is necessary to buy promotional/marketing material, go to seminars for training, buy some product to demonstrate with, etc... We are very open and upfront, we have secure web sites, we do not spam, harass, or "high-pressure" sell anyone. VEMMA tries very hard to be professional, eliminating the $500.00 threshold,would make it very hard to garner new prospects. The whole proposed rule-change seems to paint everyone with the same brush of distrust. Litigation reporting should only apply if there has been some judgement against you relating to the business opportunity. If you were on trial in a criminal court the prosecution is not allowed to intoduce prior "bad acts" unless the judge rules that they have some relevancy, the same rule of law should apply here. Earnings claims should always be followed by a disclamer, that individual results will vary. They vary because many people are not looking for a business opportunity, they are looking for a lottery ticket. The reason that they fail is because they do not do any work, and sit back looking for the money to come rolling in by the truckload. It does not work that way and all of us that are legitimate know this, and tell any prospective person this same thing. I'm not going to give anyone access to my bank statements to prove that I make what make. I've already been the victim of identity theft once and the requirements that you are proposing would leave me wide open once again. I'll close by saying that I came into direct sales so I would not have to worry about my job getting sent overseas,(already happened) not having to work for a boss who has no sense of anything but the bottom line, and mainly to work with people that have a genuine desire to make things better everywhere. Freedom is very precious thing, freedom to earn all that we are capable of earning legally, freedom to help others, freedom to have leisure time, take vacations, give more to our places of worship; we take all these things VERY seriously. I hope that we can work out a reasonable solution, that enhances these freedoms and does not eliminate the abilty to make our dreams come true!