| Comment Number: | 522418-10395 |
| Received: | 7/16/2006 11:46:02 AM |
| Organization: | Glaus Ventures, LLC |
| Commenter: | Franz Glaus |
| State: | MT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom it May Concern, I have been a representative with WorldVentures, LLC of Plano, TX for 7 months and in that time have personally recruited about a dozen people and they have recruited ten more. I believe the company offers excellent products and services and gives excellent training to those who wish to represent them. Never have I felt that they misrepresented anything at all. This company also gives me the opportunity to develop a business from home that, over time, will allow me more financial freedom and more freedom of my time to enjoy with my family. I appreciate that the FTC is seeking to protect the consumer and the public in general. However, I find that the requirements of this rule will unfairly impact legitimate direct selling businesses like mine and other WorldVentures representatives that I have helped get started. Specifically, the seven day waiting period casts our business plan in a bad light; it necessitates burdensome and unnecessary record keeping; and it creates delays in the sales and recruiting process which are detrimental to my business. One of the reasons I, and virtually everyone I recruited, were able to start up in WorldVentures, was the small financial risk involved. To make us comply with rules that are meant for higher risk franchise ventures is unfair and overkill, in my opinion. The litigagion reporting aspect of this rule seems unfair in that it doesn't distinguish between winning and losing lawsuits. It seems that the reporting of all litigation regardless of the outcome would be irrelevant to the pre-enrollee seeking a new business opportunity and puts unnecessary burden on the business. While I agree that I should never make earnings claims I can't back up, the rule requires data that is difficult to collect and the bad apples out there won't be deterred but my legitimate business will be unduly burdened. It's impractical, to say the least, to find the "10 nearest existing sales people" to refer the new pre-enrollee to, not to mention how my "10 nearest existing sales people" will feel about having to provide their contact information for such a purpose. It seems to me an unreasonable rule and will discourage people from being a part of such a business, which is otherwise such a great opportunity for personal growth and freedom. Please reconsider this rule as it absolutely presents the kinds of obstacles that are not only unnecessary but quite detrimental to my ability to grow my business. Yours truly, Franz Glaus