| Comment Number: | 522418-08392 |
| Received: | 7/12/2006 6:08:54 PM |
| Organization: | Independent Distributor Xango |
| Commenter: | Frances Schermerhorn |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: Business Opportunity Rule, R511993 I am an independent distributor with Xango. This rule would impose some requirements; which would be nearly impossible for me to comply with and others that would have a very negative impact on my business. First, I do not have a list of all the Xango distributors nor their geographical locations and as the number of distributors is increasing daily how could I possibly give prospective distributor a list of the ten nearest purchasers. Second, as many prospective distributor’s want to test the product before introducing it to others or may just want to purchase Xango at wholesale prices. The seven-day waiting period is unreasonable for the minimal $35.00 charge to become a distributor. Third, I do not have information regarding the number of people who are distributors with Xango nor, those who have canceled orders, nor those who have canceled their positions a distributors. Personally, I experienced a computer clinch where one of my orders was duplicated and I needed to cancel one. Inclusion of this type of cancellation could be very misleading. Fourth, unless the FTC can insure that income claims statements are accurate they should be left out. Anyone can make a false claim about how much they are earning and back it with a false statement. It is not how much I make that is important to a prospective distributor, rather how much they can make. Finally, I am a bit confused regarding the legal actions requirement. Does this refer to only the individual distributor or does it refer to all the distributors in a given company? If I were selling my own personal distributorship for thousands of dollars I could understand at least some of these requirements. However, since we are just offering people an opportunity to earn a reasonable income with a nominal startup cost, these rules are unreasonable. Sincerely, Frances E. Schermerhorn Xango Distributor #9210187