| Comment Number: | 522418-07121 |
| Received: | 7/9/2006 2:25:05 PM |
| Organization: | Xango- SUPPLEMENT to tracking # 522418-06852 |
| Commenter: | Judy Katz |
| State: | VT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Concerning the requirement of the list of nearest references, this could well cause me not to get involved in a home business because of privacy and safety concerns. I think I understand your position on this, but disclosing this info to just anyone, e.g. a prospect, puts me and my household at risk personally. In the selling process I don't know my prospects, have no history w/them. I am just learning about them myself. I’ve just met them by phone or email when they contacted me for info from my advertising. This prospect could be anyone, legitimate and with integrity, or not. This reference info could be used for any reason. Competitors, perverts or stalkers could pose as prospects. Prospects could harass me by continually calling. They could retaliate based on my responses. This would be a list for everyone’s prospects. I am currently a distributor in several businesses. Although I am not active in most, that puts me at risk in several different enterprises for people to be calling me. If I choose not to be a distributor anymore, then I have to pay higher prices to get the products that I use daily. In this age of privacy concerns, this provision is an anomaly. I consider this an invasion of my privacy. If I question the integrity of my prospect, or feel that he may be a blamer, I will cancel him out as a prospect, rather than give him the list of people in his area. That would be a disservice to the prospect because he will not receive the benefit of the doubt. I have always investigated businesses by listening to the corporate presentation calls and then speaking to other people via 3-way conversations, with my marketer introducing me to others to discuss product and their personal experiences. All the businesses I have ever looked at or participated in have provided this 3-way feature. This is standard procedure in this industry. It’s the way businesses introduce prospects to people already in the business and still protect people’s privacy. If anyone locally is contacted under the proposed rule, would their responses be any different? They are still in the business and giving their testimony. I have been contacted locally in some rare instances. I gave my experience to that prospect the same as I always gave it on a 3-way call in the ordinary course of the selling process. In my experience, it's not the representations of success that are the problem. I have always found those representations to be honest and truthful. It's just that not everyone can or will achieve the same level of success because of their work ethic. The problem is not the risk of fraudulent misrepresentations of income and success, it is that in our society some people blame everyone and everything else for their lack of success, instead of figuring out what they need to do to become successful, and then doing it. They are not willing to work. They assume that success will come easy because other people are successful. When it does not, they start blaming. Every business I have ever looked at or worked has qualified the representations of income potential so that people know that success depends on them. The home business industry and entrepreneurial spirit with extraordinary products and innovation is alive and well because of network marketing and direct selling. It provides the little guy with the opportunity to build the better mousetrap and get it marketed without the prohibitive costs of national advertising and the middleman distribution system. Please do not close off this avenue of prosperity to our country. It allows people to get started from the comfort of their own home, on a shoestring, and become successful. It’s one of the few bright spots of hope to me, and I am sure to others, in our economy with the current economic landscape and outlook. Thank you for your consideration. Sincerely, Judy Katz