|Received:||7/14/2006 1:26:42 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been involved in this business for nearly ten years.As an attorney, I suggest that if the business was not significant, I would not be participating for this length of time. Prior to registration, appropriate disclosures are presently required. The new business owner can recieve a refund if not satisfied. There should be a reasonable cancellation policy. Registration cost is typically around $160.00, depending on the product sample pack chosen. A waiting period would significantly impact and unduly interfere with the stream of commerce. I suggest no other business has such a stringent requirement and one is not necessary here. In the era of frivolous litigation, a litigation disclosure requirement would also be unduly burdensome. I suggest that you require the same disclosures to the Auto manufacturers re: safety Litigation. Regarding financial disclosures and earning disclosures, disclosure of personal income can more than likely be misleading. . There should be standard simple income disclosures that apply to all direct sales Companies. Requiring references would be contrary to the structure of our business. Thank you for the opportunity to be heard.