Comment Number: 522418-09130
Received: 7/13/2006 11:36:17 PM
Organization:
Commenter: Barbara Moyher
State: PA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear Sir/Madam, I am writing in reference to the proposed New Business Opportunity Rule R511993. Although the proposals are well intended, these actions will in fact be a huge burden to legitimate and caring small business owners like me who provide free market trade and help others to build additional household income for ourselves and our families in this time of great job insecurity. It will actually punish those of us who offer a service and destroy our credibility with even more suspicion of our industry while doing little to resolve the problems that unscrupulous people have created through fraud and misrepresentation. I oppose the 7day waiting period because it is excessive and adds an unnecessary burden to all involved in the process. The start up fee in my business is very minimal as is in most direct sales businesses which is part of the attraction as business expenses go. Most companies already have a money back guarantee if the customer is unhappy and if they don’t they should which would eliminate the problem. We as consumers purchase all kinds of things without having to wait 7 days. This is a ridiculous proposal. Income claims - If the seller or company states or implies a specific level of income I would support that it be substantiated in writing with an average earnings income statement. However this requirement would not deter fraud. A fraudulent company will not provide accurate data while legitimate business opportunity sellers will have difficulty in meeting the proposed requirements. In disclosure of previous litigation - I support this only if the parties involved are found guilty. I oppose the disclosure of such information if the defendant is found not guilty or if the opposing parties agreed to settle without admission of guilt. Business references requiring the disclosure of a minimum of 10 purchasers closest in geographical location. - While it is good practice to provide references of satisfied customers, this is not a practical solution in this day and age of internet business. Providing the names and contact information is a violation of confidentiality. People are guarded and fearful of identity theft and should not be required to make public their choices in the companies they patronize. Again it will be an unnecessary burden for the small business if made a requirement while invading the consumer’s privacy and it may threaten the entire business relationship of all the parties involved. Voluntary participation would certainly be welcomed and supported but not as a requirement. Again the money back guarantee enforced should protect the consumer so they can make up their own minds in choosing to participate. I have been involved in the network marketing industry for over 12 years and have met the finest people and been introduced to the best products that have made a huge impact on myself and my family. I love to share information that may help others and give them the opportunity to benefit as I have if they so choose. This is a wonderful industry and is one of the few ways the average person can get ahead and contribute to the economy while having the freedom to have well needed family time and income security. Please don’t let the actions of a few in this industry devastate those of us who have the best intentions of helping others. I thank you in advance for reviewing and posting my comments. Best regards, Barbara Moyher