|Received:||7/13/2006 9:24:24 AM|
|State:||Not in the US|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Having read the proposals for consumer protection by the FTC, I would first want to comment that I fully endorse the intention to protect the consumer against fraudulent business practice. Indeed my business started from being a consumer myself. Both from a consumer’s standpoint and from a business owner’s perspective, it is of utmost importance that fraudulent and unscrupulous individuals or groups should be identified and prevented from doing harm to a legitimate and democratic industry. A teacher by profession, this business has become a natural progression from academic education to teaching people about health and how to look after their financial needs. This has enabled people in my sphere of influence to overcome debilitating health conditions, develop confidence in themselves, get out of financial debt and spend more time with their families. I believe that empowering people to take care of themselves is the way to combat debt and deprivation, prevent chronic illness and gain personal growth and understanding among world communities. The company that I joined is of impeccable repute and conducts all its business ethically, legally and in every respect appropriate to the needs of consumers. This is by no means the only such company. In all areas of business unscrupulous individuals will find a niche: from the street level to multinational corporations there are self serving opportunists with no regard for their fellow humans. In view of this, controlling organisations such as the FTC have an extremely important function. The difficulty, however, is in finding the correct balance between legislating for the legitimate corporations and against fraudulent practitioners. This industry relies greatly on immediate access to product and business opportunity and the seven day rule would cause delays, which would cast our business plan in a bad light. This would also make for burdensome and costly administration, which would have to be carried over to the end user: the consumer and distributor. The requirement to provide a list of nearest purchasers is impractical because we have purchasers all over the world and will have to contact our company who holds the data of purchasers before we can offer the opportunity. This will cause further delays to the seven day rule while the data base is searched and information exchanged. More importantly, I see this disclosure endangering the privacy of the purchasers: this information would have to be given to anybody who claims an interest in purchasing or participating in the business opportunity. Any fraudulent company could provide fraudulent references. Prospective purchasers will be deterred from participation for fear of disclosure of their personal data. If the distributor is to divulge this information, who would then be responsible? The distributor builds the business on limited investment, which is the whole point of multi-level marketing. I couldn’t afford the responsibility of a law-suit for identity theft. I have outlined some areas where I can see that the proposed rule will be detrimental to this industry.. This is a business that is built over time on a part time basis. There are over 13 million people whose lives have been positively changed by this industry. Their livelihood now depends on the years that they have invested. Although I fully support the FTC’s mission, I feel that legislation to change this growing industry is best served by identifying the legitimate business corporations and consulting with them to find the best practicable solution for the protection of the consumer and legitimate business owner.