| Comment Number: | 522418-08725 |
| Received: | 7/13/2006 11:37:46 AM |
| Organization: | XanGo, Independent Distributor |
| Commenter: | Lindsay Ingalls |
| State: | NC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Lindsay Ingalls Dear Federal Trade Commission: I thank you for your efforts to save our citizens from fraudulent pyramid schemes and unethical business people who take advantage of people wanting build a home business. However, I see that certain details of this proposed rule will significantly damage legitimate business opportunities in America, while fraudulent businesses will commit more fraud and survive. I began in the direct sales industry with XanGo in 2005 as a Sales representative and continued as a Sales Manager. I have met extremely ethical and hard-working people in XanGo. I have gained confidence in my interaction with people. I gained public speaking skills and sales presentation skills, and interview skills. I taught over 29 years in the North Carolina public schools. I retired in February 2006 and I am supplementing my retirement income through my home business. My direct sales business enables me to supplement my income whil providing flexability to be able to keep my grandchild. I love the idea of this business because it is possible for me to develop a full time income while I help people to discover a product that may increase their health. The Direct Selling and Multi-Level Marketing companies are wonderful companies that allow people with passion, work ethic, and a willingness to grow to develop a business whereby, with low capital entry, they can develop a lifestyle of time and money by helping and educating people about useful products and services. All of the direct sales companies I’ve encountered make “The Golden Rule” part of their business philosophy and this proposed rule will negatively affect their ability to help people. Were it not for the low entry fee, I would not have been able to have this opportunity to build my own home business. The seven-day waiting period will put a damper on anyone wanting to get started. With the speed people can collect information, a 7 day waiting period is an unnecessarily long length of time. Many negative people often do not have open minds to business, and spoil a person’s drive to get momentum in the beginning. This casts direct selling in a negative light. It makes legitimate businesses look like we need more time to make sure we aren’t doing anything wrong. If the $500 business threshold is eliminated, it will place most direct selling companies in a category that they do not fit. The beauty of direct sales and MLM companies is the ability to have extremely low capital investment, and leveraging the efforts of many people to sell products and services. It is an industry that does not need a high initial investment. It would force many to comply with rules that are more appropriate for businesses requiring a greater investment than a sales kit. Another part of the proposed rule that would affect any business is the litigation reporting. In a world where it is ideal that people are innocent until proven guilty but they are mostly assumed guilty until proven innocent, and in a world where more litigation goes on than ever before, it seems unfair to the innocent parties in the litigation process to make it possible for people to judge the fact that someone is, or has been litigating. It does not distinguish from winning/losing lawsuits and the litigation may not even be relevant to the business. Next, the idea that a business person should be required to provide the 10 nearest existing sales people as references is highly impractical because often you meet people away from home. It also flirts with violating privacy and safety issues as this information would have to be given to any prospect, and it may even create the potential for ID theft and corporate liability. I would ask that you look at many of the rules that will put legitimate home businesses such as mine in a position where it is difficult, if not impossible, to build a direct sales business . Sincerely, Lindsay Ingalls