|Received:||7/11/2006 3:04:05 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am writing to you about the FTC's proposed Business Opportunity rule (16 CFR Part 437). As an Independent Associate of Pre-Paid Legal Services, Inc. (PPL), I am concerned because this rule would have a very negative effect on my home-based business and income. The FTC's proposed rule would require a seven-day waiting period before a person wanting to become new PPL Independent Associate could sign up as such. This requirement will cause me unwarranted record keeping and administrative problems, and will have a chilling impact on small businesses. The FTC seeks to require me to provide the names and telephone numbers of the ten nearest prior purchasers of the Business Opportunity to all potential Associates. This disclosure will violate the privacy rights of the prior purchasers and could provide opportunities for identity theft. It would also require me to ask for the list from PPL each time I want to sign up a new Independent Associate - - which will create an enormous administrative burden on me. The FTC's proposed rule would require me to provide a list of lawsuits filed against the company going back ten years. This is unfair, does not distinguish between allegations and findings. By requiring this kind of disclosure going back ten years the FTC allows meritless lawsuits to turn into winning lawsuits. Again, an enormous administrative burden on me and other small business people. While the FTC's proposal may be well-intentioned, I believe it is ill conceived and would have a dramatic negative impact on many or most small businesses. The proposed rule would unfairly target legitimate, publicly held, direct selling businesses like Pre-Paid Legal Services, Inc. Thus, I urge the FTC drastically change the proposed rule.