| Comment Number: | 522418-06330 |
| Received: | 7/5/2006 11:42:33 PM |
| Organization: | Business Services Group |
| Commenter: | Raymond Sandborgh, Ph.D. |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
In your document you refer to "pyramid marketing schemes" and avoidance of franchising laws as a major threat to business and cousumers. In reading Federal Register: April 12, 2006(Volume 71, Number 70)][Proposed Rules][Page 19053-19096], it became clear that you are proposing "solutions" that create as many problems as the proporte to solve. Much of the information you would require provides no way of telling if a business is a fraud or not. Also, it can be simply hard to help persons with no business experience tell if the terms and conditionsa are going to thelp them make a profit or not. I simply will not consider working in a relationship where one side can change the compensation structure . Yet, people hare making money in such business. In summary your requirements are onorous. I think you need to start over. Rethink the problem from policy cost benifit perspective. How far above simple "noise level" is the problem? (For example, when unemployment is around 3%,it may cause a lot of personal pain to be unemployed, but economic systems simply are not perfectly efficient and 3% is a noise level of enemployment. Perhaps, a positive certification program would be better. It seem to me a voluntary program of certification standards and public information would be effective. The FDA is sort of an example. I do not think one should need federal approval to begin a business. But, it would be like a Good Houskeeping Seal of Approval on one end and careful legal restrictions with suitable penalities on the other. Please, reconsider what you are proposing. As i read it a lot of good working buiness would simply cease to exist if these Proposed Rules move forward in anything like their current form