| Comment Number: | 522418-06358 |
| Received: | 7/6/2006 1:01:03 AM |
| Organization: | Miedema Developments |
| Commenter: | Angela Miedema |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I would like to submit my comments on the new FTC Proposal for fighting fraud within the "home-based" business world. While I applaud the effort and agree that something must be done to stop the scams that are running rampant in our country I am not convinced that all of the proposed rules are fair or even helpful in reaching that end. The 7 Day Waiting Period - this proposal seems very restrictive to me and will not really do much to fix the problem. It will however slow the very crucial initial momentum of legitimate brand new business owners. Those first few days when you are on fire is the most important time for gaining confidence in your ability to succeed and having to wait 7 days or see your new prospects have to wait could certainly grind your business to a halt. Instead consider encouraging businesses to make a 7-10 day cancelation policy available, that way people still have an out if they feel they made a bad decision but otherwise they can proceed with their business unhindered and with their excitement in tact. Requirement to Provide References - this rule just does not work well for most of the multi-level marketing businesses. While it could possibly stop some fraud, any good scam will have a list of people "paid" to be references. However, honest business owners having to give out a list of other people in their business would be most upset. What if after all the work you put into a prospect they talk to a reference and decided he drives a nicer car or has a funnier peersonality and they get in business with him instead. Is that fair to the business owner who put in all the ground work educating the prospect? Not to mention, in my business at least, we already greatly encourage our newest prospects and business owners to attend a business meeting to make sure they are well educated and to meet people in the business and decide if this is right for them...so this rule would be redundant for our case and that of many others. Proposal to Provide a Litigation List - this is just plain silly guys. Most of us small business owners by our products and/or services from a larger manufacturer but we have nothing what so ever to do with any cases that may be filed against them. Would you really ask your neighborhood grocery store that sells Cheerios to provide you with a list of all litigation against General Mills? Think about it. :) Requiring us to Provide Specific Earnings info - this rule also seems very redundant, at least in my business. We already provide our prospects with a very straight-foward income disclosure that shows averages of the income of the people participating in our business at various levels. To put this rule through would be more paperwork and headache for legitimate businesses and again if a scam artist is involved how easy would it be for them to fake this? Requiring Personal Financial Records - This is probably the worst thing you could do to honest struggling business owners. When you are fighting tooth and nail toget your business off the ground you do everything you can to convey an image of success. This does not mean lieing to people but your exact success level in a business has nothing to do with what they can achieve and in showing them the exact financial figures of where you are at may discourage them if you are just starting out. It would create a real roadblock for all new business owners. Instead we project success (which is common in all areas of the business world) and then we slowly build our businesses up to that level, never being dishonest but hopeful and optimistic for the future. Anyhow, that is my 2 cents worth on the issue. I truly hope that you listen to the small business owners of this country as they make ideas known to you. If you don't do this right you could drastically affect not only my future but the very economy of the small business world and eventually all of America. Thank you for your efforts! -Angela Miedema