| Comment Number: | 522418-07814 |
| Received: | 7/11/2006 7:34:57 PM |
| Organization: | XanGo Independent Distributor |
| Commenter: | Michael Wagner |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: BUSINESS OPPORTUNITY RULE July 9, 2006 Dear Sir or Madam, I am gravely concerned about the proposed Business Opportunity Rule R511993. I believe that in its current form, it could seriously hurt me as an independent distributor with XanGo, LLC, a half billion dollar company headquartered in Utah. I believe that it could possibly destroy my small business. I have operated a home-based business through XanGo since November 2002 and currently earn $100,000 a year, the primary money that supports my family. To build my business, it took a lot of hard effort. In one fell swoop, this rule threatens our entire livelihood. PLEASE DO NOT DESTROY MY SMALL BUSINESS! MY FAMILY NEEDS IT! The seven day waiting period clause of Rule R511993 unfairly raises suspicion on my business, encourages prospective entrepreneurs who wish to join me to lose their focus and enthusiasm, and is UNNECESSARY! Unnecessary because it only costs $35 to join XanGo. Unnecessary because our products $100 for a case of XanGo comes with a complete 30 day money back guarantee. People buy TVs, cars, and dozens of other consumer items that cost much more and do not have to wait seven days. Why should this law being imposed on my business which costs so much less? In addition, Rule R511993 requires that I keep detailed records or when I speak with prospects, that I send those records into my company. I am a small home business and this burden creates a MOUNTAIN OF PAPERWORK for me. I can’t even imagine what XanGo will have to contend with, should they have to receive this kind of paperwork from their 500,000 associates!!! Finally, Rule R511993 requires that I provide a minimum of 10 prior purchasers nearest to the prospective purchaser. This is UNBELIEVABLE! Not only is this truly a nightmare for our record keeping, but presents an UNACCEPTABLE BREACH OF CONFIDENCE AND PRIVACY for all our customers and distributors. In this age of identity theft and personal privacy concerns, it is truly horrifying to require that the names and personal information of people in my customer and sales organization be shared so freely. This is unacceptable to women in particular, whose disclosed information could lead to harassment. Moreover, this rule allows competitors to pose as potential buyers in order to "steal" our customer and distributor base and their data. Indeed, there are scams and con artists which should be properly dealt with and put out of business. BUT THIS RULE WILL NOT STOP TRUE CRIMINALS. Perhaps there is some wisdom to implementing some of these guidelines for business opportunities that require large investments. But at the very least, businesses like mine which take much less than $500 to start and which provide average American families extra income possibilities should not be subject to such BUSINESS KILLING MEASURES by our government. At the very least, I'd propose that this rule ONLY apply to businesses that require substantial investments, perhaps $1000 or more (?). PLEASE DO NOT ALLOW THIS RULE TO GO INTO LAW as it is currently written. PLEASE DO NOT JEOPARDIZE COUNTLESS HOME BASED BUSINESSES LIKE MINE!! AGAIN, OUR FAMILY DEPENDS ON THIS INCOME AND THIS RULE WOULD BE A DIRECT ATTACK ON OUR LIVELIHOOD! Sincerely, Michael A. Wagner