| Comment Number: | 522418-06676 |
| Received: | 7/7/2006 12:22:45 AM |
| Organization: | |
| Commenter: | Alan Eames |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Federal Trade Commission/Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it could prevent me from continuing as an Associate of Pre-Paid Legal Services, Inc. and destroy my small business. I have been an Associate for more a year now and plan on continuing so for a long time to come. Some of the sections in the proposed rule would make it hard or almost impossible for me to sell my company's services. This waiting period will give the public the idea that there’s something wrong with me or our plan. I also think this seven-day waiting period is unnecessary, because most companies already have a 90% buyback policy for all products including sales kits purchased by a salesperson. In the instance of Pre-Paid Legal Services, there is no product to buy back as it is a service that is cancellable anytime because it is a month to month service, no long term contracts. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new Associate . Pre-Paid Legal's sales kit only costs $249. People buy TVs, cars, and other items that cost much more than that and they don’t have to wait seven-days. Under this waiting period requirement, I will have to keep very detailed records when I first speak to someone as a prospect and will then have to send in reports to my company. This is ludicrous. I am a small home business and this rule will burden my ability to do business. This proposed rule is bad. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, but do not feel it is ethical to give out the personal information of individuals (without their approval) to strangers. Women in my organization may be subject to sexual harassment and men & women could be subject to racial harassment so this part just has to go away. Any ethical distributor would happily give references, this is not necessary. Unethical distributors are going to give unethical references, I don't see anything to be gained by this part. This rule will do nothing to stop criminals in our industry, but it will certainly harm the honest distributors. And they will hurt my business! Thank you! Sincerely, Alan Eames