| Comment Number: | 522418-06945 |
| Received: | 7/8/2006 3:01:22 AM |
| Organization: | Ameriplan USA Independant Business Owner |
| Commenter: | Batina Eklund |
| State: | WY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sirs or Maam, I am writing in regards to the FTC's proposed business opportunity rule; R511993. I believe that as it is worded now it will hinder my growth as an Independant Business Owner with Ameriplan USA. I understand that part of the FTCs responsibilities is to protect the public from unfair and deceptive acts or practices, but some of the sections in the proposed rule will make it very difficult if not impossible for me to sell Ameriplans wonderful business opportunity. Although a great deal of income comes from direct sales of the product, new business partners are a very important and substantial portion of my business. I find three major problems with the proposed rule. First, the seven day waiting period is both burdensome and unnecessary. Our initial investment is under $100.00. People spend much more money on TV's, cars, and other items everyday without waiting periods. This portion of the rule would also cause a great deal of extra paperwork for me as well. Since my time is best spent talking to people the burden of these extra administrative duties would decrease my profits by taking me away from my prospects. They would also make my days much longer.........taking me away from my family more. . Secondly; the proposed rule also calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not have to specify whether those claims were substantiated or not. Our society today is "sue happy." Because of this there are many frivilous law suits. I feel we should only have to provide information on those that are substantiated. Ameriplan is listed with not only the Better Business Bureau but also the United States Chamber of Commerce. Every potential business partner has the opportunity to research the company through those entities. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am happy to give references but only with my business partners permission. Remember, we are not sure that these prospects are truly going to become partners. Giving out such information could result in breech of confidentiality and possible identity theft. I personally would not like my contact information given to anyone that happens to be nearest me. I believe that to be a safety hazzard as well. This would also cause more administrative duties requiring us to contact corporate offices of a list of the nearest business owners. This is time consuming and honestly a waste of time. Requiring that business opportunity companies be registered with the Better Business Bureau would be a much more effective way to provide references and litigation information. I have been a part of the Ameriplan family for over one year now. It's an upstanding company with an awesome reputation. The "good players" should not have to suffer for the "bad players." Putting these rules in affect would drastically change how I do business and puts in jeopardy the income that my family has become accustomed to. I appreciate the work of the FTC to protect consumers, but I believe this proposed new rule has many unintended consequences and that there are less burdensome alternatives available in achieving its goals. Thank you for taking the time to consider my comments. Sincerly, Batina Eklund