Comment Number: 522418-10561
Received: 7/16/2006 5:35:57 PM
Organization: Ronalsha Enterprises
Commenter: Alvena Pauls
State: Not in the US
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

To Whom It May Concern: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it would prevent the business I operate from continuing as a XanGo™ Independent Distributor, and would destroy the small business I am working so hard to build and operate, as well as those of, literally, thousands of others. I have been operating this home based business, representing XanGo™ LLC, for 1 year. 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 now operating their XanGo™ businesses on a full time basis, and this is now their only source of income. Please don’t destroy these small business people who are supporting their families with their XanGo™ income alone. There are, today, thousands who are solely supporting their entire families from their XanGo™ income. Some of the sections in the proposed rule (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 fantastic opportunity under the proposed rules. Changing to the new rules would devastate the growth and profit potential of the business I operate. The proposed waiting period will give the public the idea that there’s something wrong with me or the XanGo™ business plan and also will reflect badly on me. I believe this seven-day waiting period is unnecessary, because XanGo™ already has a 90% buyback policy for all products including sales kits purchased by a salesperson. Additionally a 100% total money back guarantee, which applies to any new enrollee, is guaranteed for these new enrollees and is currently and daily exercised freely by anyone purchasing from XanGo™ within the first 30 day period. The current procedures in place by XanGo™ already insure that no one can ever be hurt financially by the XanGo™ business opportunity. One of the most difficult 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, literally, extremely difficult to build and operate a XanGo™ business. This change would stifle the initial profit and actually make operating a XanGo™ business less profitable than it currently is under the existing rules and procedures. For a new rule to stifle profit should point out the inadequacy of thought that has generated this new rule proposal. The XanGo™ sales kit only costs $35. People buy other items 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. XanGo™ distributors operate small home businesses and this burden could destroy them completely by requiring excessive paperwork, and requiring a person to be a superstar instead of being just an ordinary person seeking to get ahead. With these new proposed rules, the XanGo™ opportunity would cease to be for the average person and would require one to be an aggressive and capable business person in the beginning. This is exactly opposite to 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 (without their approval) to strangers. Women in my organization may be subject to sexual or racial harassment so, unless the FTC passes an addition to this rule prohibiting sexual or racial attacks related to this disclosure it will open up women to sexual attacks and/or stalking. In the end this rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. Also, sharing names and addresses of existing distributors with a “prospect” would open an organization to being attacked by other businesses. A person from another sales organization who wished to proselytize an existing organization would literally be given the key to the bank….it would be like hiring the fox to protect the hens in a hen house. Why would any person in his/her right mind feel sharing existing contacts and/or customers with their competition was in their best interest? Daily I see many scams on the Internet and I have been approached by many crooks because of my success. The proposed rule R511993 will do nothing to stop these unscrupulous crooks. They hurt my business! This rule will not stop Crooks – they violate the current rule all the time. But I am a good Canadian citizen and the 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 a good company, please do not lump great companies like XanGo™, which has a 100% money back 30 day guarantee, into the same barrel as those who currently take advantage of others daily with no repercussions. If you wish, go after those who are damaging or hurting innocent people. Please insure that any proposed rules will not be detrimental to the incredible volume of sales created by the Direct Selling Industry, a Multi Billion Dollar industry today. May I humbly suggest that you or your representative visit the XanGo™ LLC headquarters in Utah and see what kind of passionate and caring company this is? You will be shocked to see a company which has the hearts of everyone in their minds, and one that would never place an individual in peril financially. Most respectfully, Alvena Pauls