| Comment Number: | 522418-09719 |
| Received: | 7/15/2006 12:33:46 AM |
| Organization: | XanGo |
| Commenter: | Harry Wilkes |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
7/15/06 To Federal Trade Commission Re: Business Opportunity Rule, R511993 To Whom It May Concern: Thank you for being concerned about keeping the American marketplace a level playing field, fair and open to all who obey the law. Yours is certainly sometimes a thankless job. You are appreciated. I began in the direct selling industry in the 1970’s and have had many wonderful experiences and developed some of my closest friendships in this industry. The confidence I have gained through the mentoring and experience in this industry has spilled over successfully into every area of my life. Direct selling even helped my wife and I keep our son in college when I was a victim of downsizing in the mid 1990’s. Whether it is in business, the practice of law, law enforcement, the clergy, education, government, medicine, etc., there are honest and dishonest people. I found that to be true even during a 28 year career in the military. Dishonesty is typically a characteristic of a limited number of individuals who might be a part of one or more companies, but not an entire industry. Otherwise, experience tells us that such an industry could not survive the vast amount of negative publicity that would be brought against it. Such is not the case with the direct selling industry. This is an industry that has thrived for more than 50 years and has had a very positive impact on the marketplace. The seven-day waiting period would put an enormous record keeping burden on small business owners when all legitimate direct selling companies have a generous refund policy for customers or distributors who change their minds about participation or purchasing. In my state of Florida, I only have three days to change my mind after buying a $30,000 automobile. But your new rule would require the $35 transaction that my direct selling company charges for a distributor kit, to be subject to a seven-day pre-notification process. One other area that I would like address is the burdensome process of finding the 10 nearest existing sales people and the privacy and safety issues of identifying them to another person. The direct selling industry provides full-time and part-time incomes to many people who would not choose to have their personal contact information be public. Let’s find the criminals in this industry and prosecute them to the fullest extent of the existing laws and provide national news coverage for these cases. I feel that would be an effective way to accomplish what your agency is charged to do. Then the vast majority of direct sellers who are honest, hard working small business people and account for a significant amount of the economic activity in our country will not be burdened with rules and regulations that would only need to be applied regarding the dishonest few. Thank you for considering my thoughts. At the age of 64, I choose to continue working and contributing to my fellow man, your new Business Opportunity Rule, R511993 would make that a difficult undertaking. Please consider the suggestions of the vast majority of honest people in this industry and listen to our suggestions. Sincerely, Harry Wilkes