| Comment Number: | 522418-06640 |
| Received: | 7/6/2006 10:59:11 PM |
| Organization: | MonaVie |
| Commenter: | Scott Thompson |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dr. Sir or Madam: I am submitting these comments over a deep concern I have regarding this proposed Business Opportunity Rule, R511993. I've had the priviledge of being involved in the network marketing and direct sales industry since 1997. It has given me my full-time career since 1998. Because of the positive impact I've seen this industry have on so many people over those years, we also engaged in industry-wide training. We did this at no cost for anyone in the business opportunity/network marketing industry. I bring this up because I believe I have some understanding of the spirit of what this proposal in trying to accomplish. I too understand that, like in so many things, there are all types of scam artists, etc. that try to align themselves as being of the same model as legitiment business. Seeing that, and being moved by all the positive things we saw with thousand of people in legitiment networking companies compelled us to teach the truth of this wonderful industry. I am very proud to represent a company, MonaVie, because they have a product that has had a tremendous impact on my health, my family and so many that we've been able to share it with. That is why I am involved on the business side of this company. The president of this company ran another company through the 1990's. Today that company is a well-respected publically-traded company that has impact many people's health and provided a legitiment opportunity to tens of thousands of people (USANA). This gentleman, Dallin Larsen, was a board member of the DSA. These, and hundreds more like them, represent the best of America in products, business ethics and a very productive and efficient business model. I am a customer of several other direct sales companies. I love some of these products and services and the independent reps that shared them with me make a commission and I'm happy to help them, because they provided my with a great service. This proposed rule places an undue burden on these companies and their independent distributors. I'm not certain it will affect the negative activity that it seeks to control. To adversely impact such a large industry, good companies and literally millions of independent distributors to try to address scam artists, etc. is not serving the public. For example: Changing the "$500 rule" to "0" doesn't do anything for crooks. The seven-day waiting period casts an unfairly negative light on good companies, generates more paperwork, and interferes with good people who want to get started. Everyday people buy appliances, autos, etc. without having to wait a week. Yet, someone how likes a product needs to have the government tell them to wait a week for a $39 distributor kit, a little product to sample and get started in what is clear to see a very simple and legitiment business? The requirement for references in an area is not only a cumbersome task with questionable purpose. But it has raises serious liability questions with disclosing people's information. With identity theft and personal security concerns, the rule itself could be opening up more potential criminal activity than it's stopping. I simply have such a high level of respect for the majority of the companies in this industry and concern for the negative implications to the millions of Americans who choose to represent the products and services of these companies, that I have great fear of the completely unnecessary damage that this rule would clearly do. All the while, I simply don't see it making enough of an impact on it's target. The balance is so grossly weighted in this issue. It must not go forward in it's current form. The clear risk for damage is simply too high. Crooks will still do what they do. I respect the intent of this proposal. However, let's not punish so many American companies and citizens. I am certainly one that fears the clear adverse implications. Sincerely, Scott Thompson