| Comment Number: | 522418-09513 |
| Received: | 7/14/2006 5:01:27 PM |
| Organization: | Independent Distributor of XanGo, LLC |
| Commenter: | Richard Pietsch |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am deeply concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it would inhibit my ability to continue to operate as an Independent Distributor with XanGo™, and would destroy the small business I have worked so hard to build and operate. I have been operating a home based business, as an Independent Contractor representing XanGo™ LLC, for almost 2 years now. I contracted to operate this business because I loved the product and wanted to share it with others. Many of the people I have introduced XanGo™ to are also operating their XanGo™ businesses on a part time basis, and they are very dependent on this income every month. Please don’t destroy what I and these small business people have worked so hard to build and operate. Some of the sections in the proposed Rule 511993 would make it hard or almost impossible for me to sell the XanGo™ product and would make it especially difficult, if not impossible, to introduce others to this fabulous opportunity. Changing to the new rules would devastate the growth and profit potential of the business I operate. The proposed waiting period will give the general public the idea that there’s something wrong with me or the XanGo™ business plan and will also reflect poorly on me. I believe this seven-day waiting period is unnecessary, because XanGo™ already has a 100% total money-back guarantee in place for any new enrollee within the first 30 days in business. The current procedures in place by XanGo™ already ensure that no one can ever be hurt financially by the XanGo™ business opportunity. One of the most troublesome sections of the proposed rule is the seven day waiting period to enroll a new distributor. The procedures associated with the proposed rule change would make it extremely difficult to build and operate a XanGo™ business. The XanGo™ sales kit only costs $35. People purchase many items on a daily basis that cost much more than that and they don’t have to wait seven days. 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. I'm operating a small home-based business and this burden could destroy my business completely by requiring me to do excessive and unnecessary paperwork. I work a full-time job and only have a few hours each day to work my XanGo™ business. I enjoy and work this business because the company I work for takes care of most of the burdensome paperwork for me. I do not have the time that these proposed new rules would require of me. Most people that operate a part-time network marketing business do so because they can supplement their full-time jobs with just a few hours per day/week and make enough extra money to pay for a car or put food on their table. With these new proposed rules, the majority of the part-time networker would be required to spend more time on burdensome paperwork than most are able or willing to do. This is the exact opposite of what the XanGo™ business opportunity was designed to do. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I would be glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals to total strangers. Women, in particular, could be subjected to sexual harassment or stalking. Is the FTC willing to be held liable or take action on any harassment that comes from this new rule?. Also, sharing names and addresses of existing distributors with a “prospect” would open an organization to being attacked by other businesses. No good business would give out the names of their current customers to their competitors. The proposed rule R511993 will do nothing to stop unscrupulous crooks, they already violate the current rule. This proposed rule R511993 will hurt me. Thank you and please help me retain the right to operate a XanGo™ business where the company, XanGo™ LLC already has procedures in place to protect anyone from loss of money and/or time and credibility. XanGo™ is an awesome company to represent. Please do not lump great companies like XanGo™, which has a 100% money-back 30-day guarantee, into the same category as those who currently take advantage of others daily with no repercussions. Please go after the "bad guys" but not at the expense of the "good guys". The proposed rules will be hugely detrimental to the United States economy. The Direct Selling Industry is a Multi-Billion Dollar industry. Thank you for taking the time to read this letter. Respectfully, Richard L. Pietsch