| Comment Number: | 522418-07211 |
| Received: | 7/9/2006 10:15:11 PM |
| Organization: | Pre-Paid Legal Services, Inc. |
| Commenter: | Charles Gustafson |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I’m writing this comment because I’m concerned about the proposed Business Opportunity Rule R511993. I believe, that in its presented form, it could prevent me from continuing as an Associate with Pre-Paid Legal Services, Inc., a 34-year-old NYSE company. I have been an independent Associate for more than 4 years. I originally started my Network Marketing business with Pre-Paid Legal Services because I immediately saw the benefit of having and providing others with protection against unscrupulous attorneys, and now, protection against Identity Theft, the fast growing crime in America according to your own statistics. My wife and I depend on this extra income to supplement our budget. Please don’t destroy my small business with these unfair rules. This is the only income we earn aside from the paltry amount we receive from Social Security! Some of the sections in the proposed rule will make it extremely hard or almost impossible for me to sell my Pre-Paid Legal services to those who need our family legal plans and our identity theft protection and restoration plan. This waiting period will give the public the idea that there’s something wrong with our Pre-Paid Legal Services plans and also reflects badly on me. I also think this seven-day waiting period is unnecessary, because Pre-Paid Legal already has a buyback policy for all services including sales kits purchased by new associates. One of the most difficult and unfair sections of the proposed rule is the 7-day waiting period to enroll a new Associate. Pre-Paid Legal’s sales kit only costs $49. 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 need to keep very detailed records when I first speak to a prospect and will then have to send in reports to my company. I am a small home business and this burden will hurt or destroy my business. This proposed rule is very bad! Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I’m glad to provide references, but in this day of identity theft, I am very uncomfortable giving out any personal information of individuals (without their approval) to strangers. Women in my organization may be subject to sexual or racial harassment so this part must not go in at all, unless the FTC passes an addition to this rule Prohibiting sexual or racial attacks related to this disclosure. In the end the rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. I’ve seen many scams on the Internet and been approached by many crooks because of my success. This rule will do nothing to stop them. They hurt my business! This rule will not stop Crooks -- they violate the current rules all the time. Thank you for considering this e-mail and please help me by not punishing me because of unscrupulous scammers. There are already laws against scammers. My suggestion is to scrap this proposed ruling and prosecute the scammers under the current rules and leave the legitimate small businessmen alone.