| Comment Number: | 522418-06781 |
| Received: | 7/7/2006 1:06:25 PM |
| Organization: | |
| Commenter: | Jesse McKinney |
| State: | IN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom it May Concern: I would first like to applaud the FTC for their efforts on behalf of all consumers in this country. I can see by this proposed rule you are trying to stop those who would defraud the American consumer in the name of "Business Opportunity". I do feel though that some sections of this rule would place an unfair burden on the industry. I am speaking of the Network Marketing industry; I personally have been involved in Network Marketing for more than 10 years. The vast majority of MLM companies are legitimate, and the majority of those Americans involved with MLM are also legit. The fact is that most people involved with MLM's make less then 500 a month, but that amount may be what keeps that family self sufficient. These people represent what this country was founded on. Some of these people would, I fear, quit because of the burdens this rule would place on them. Let's look at this from a numbers perspective, if just 10% of the 13 million estimated people involved with MLM stop because of the administrative burden this rule would place you would see 1.3 million people not making that extra few hundred dollars a month. A few hundred dollars a month times 1.3 million people over a years time means a whole lot of money not flowing through the economy. Some areas of the rule I feel need to be modified: 1) 7 Day waiting period -Most companies already offer a buy back period ranging from 30 to 90 days. Why not simply require the company to offer a buyback period. Say in the first 30 days the company has to buyback all purchased product. 2) Litigation -Needs to distinguish between convictions and just being sued, and that is a major difference in this country. 3) References -This would seem to be a privacy issue, plus a lot of MLM'ers does not live in the geographical area of their sponsor. 4) $ to signup -Most companies have a very low application fee (for lack of a better term) simply impose that no company can charge over x for signing up a distributor or require the purchase of product. Thank you Jesse McKinney Independent Distributor for 4Life Research