| Comment Number: | 522418-10115 |
| Received: | 7/15/2006 6:40:14 PM |
| Organization: | |
| Commenter: | James Egloff |
| State: | NV |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Concerning: Business Opportunity Rule R511993 This rule, while well intentioned, will put undue strain on my ability to operate a successful home base business. We operate with a highly respected company and feel this rule would hinder legitimate direct selling companies unfairly. My wife and I have been involved in XanGo for just over a year. Our lives and goals have been changed immeasurably by this association. We have met positive people that have inspired us to work hard, changing and growing along the way, and in so doing help others to do the same. We now see a way that we will be able to use our extra income to retire comfortably. Without this opportunity, we would have struggled to do so. A few of the proposed changes need to be addressed. Putting a 7 day waiting period into place before a new person can join is quite impractical. It adds a burdensome amount of extra paperwork and is an unnecessary delay for someone eager to enter the marketplace and build a business. Specifically, this rule makes it impossible for a new person to get started right away; after I have invited him to my home for a presentation and have all the materials on hand to help him begin. Our company's policies make it nearly risk free for someone to join at this time. Removing the $500 business threshold make direct selling companies comply with rules that are more appropriate for a franchise company where more time and money is being invested. Finally, if I am recruiting a cousin in New York and I live in Nevada, the new rule would require me to find the 10 nearest existing sales people as references. This is an unfair burden on me and the company in light of the investment required to join; not to mention the cost the company would incur to maintain this database and keep it readily available. In this case, I would have to contact the company, have them access someone's private information (requiring this to be available will limit some people's participation in and of itself) and then send it on to my cousin. I don't think the FTC should be concerning itself so intently on legitimate, low risk direct selling companies. The cost to everyone involved is too prohibitive. Even the FTC would incur costs to make sure everyone complies with the rule. Thank you for taking time to consider my comments. Sincerely, Jim and Judy Egloff