|Received:||7/13/2006 9:56:06 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am writing this because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it could prevent me from continuing as an independent affiliate with Vitamark International, a direct selling business. Originally, I started my Network Marketing career more than 20 years ago because of the products. I loved them and wanted to also earn some additional money. My family needs this extra income to supplement our budget. Please don't destroy my small business, we need it! Some of the sections in the proposed rule would make it hard or almost impossible for me to operate my business. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new affiliates. This waiting period will give the public the idea that there is something wrong with our plan and that reflects badly on me. It also hinders the operation of our businesses by causing unnecessary hardships on people who already abide by the rules. Under this waiting period requirement, I will need to keep very detailed records when I first speak to a prospect and will then have to send in reports to my company. When do I start keeping those records -- when I have a conversation in passing, or when I have an official meeting, or ... ? I am a small home business and this burden will hurt or destroy my business. In addition, the extra paperwork will add additional costs to Vitamark which will also be passed on to the affiliates. I also think this seven-day waiting period is unnecessary, because Vitamark already has a 90% buyback policy for all products including sales kits purchased by a salesperson. Vitamark's sales kit only costs $29. People buy TVs, cars, and other items that cost much more than that and they don't have to wait seven-days. I am also troubled by the litigation reporting because it does not distinguish between Civil and Criminal cases. Beyond that, it is unfair that it does not distinguish between winning and losing lawsuits. In an age of frivolous lawsuits, this seems totally unfair. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. First of all this may be impractical for persons such as me since I live in a small town and there may not even be 10 people in my area that have purchased. I am glad to provide references, but in this day of identity theft and other safety concerns, I do not think it right to give out the personal information of individuals (especially without their approval) to total strangers. Some customers might even consider this an invasion of privacy. Providing personal information of women in my organization could put them and their children at risk for sexual predators. It may also put them at risk of sexual or racial harassment. If the FTC passes this rule, an additional rule prohibiting sexual or racial attacks related to this disclosure would be needed. This rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. Of course, taking enforcement steps for this could be a moot point, because since when do many of the people wishing to harm others, allow our laws to stop them! I am happy that my government wants to rid our country of scammers and crooks as they hurt all of us. Unfortunately, this rule will not stop them – they violate the current rule all the time. Crooks that currently violate the rule which is at $500 will not be hampered by $0 dollar limit, so this rule will not hurt them. But, I am a law-abiding American citizen and these rules will hurt me! Thank you and please help me.