|Received:||7/16/2006 9:06:13 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Re:"Business Opportunity Rule, R511993 I have been in direct selling for about 15 years. Today I am with a company called Xango. I am in direct selling today for the same reason I got in originally, to make some extra money for my family, pay off college tuition and along the way try to put some money for retirement aside. The skills I have learned along the way have contributed to more success in my day job by giving me more confidence and people skills needed to fulfill my obligations to my employer. I apperciate the FTC's consumer protection priorities,however I must express concern for the impact on legitimate direct selling companies. I do understand that there are fradulant companies out there but it seems to me this particular rule unfairly targets the legitimate companies. Specifically, I think the 7 day waiting period is unfair and impractical. It casts doubt on direct selling companies right away. People are going to wonder why the government is making me wait 7 days to sign up? I don't have to wait before I agree to buy my car or most other things. There must be something wrong here. Why could I sign to take a job with a tradational employer but I cannot do this for 7 days. I can listen to or read advertising and go to a store and buy a new product, why do I have to wait 7 days here? Doesn't seem fair. Because of the number of people I may talk to in a day, possibly scattered all over the country, the volume of extra record keeping and the cost envolved makes it unfair to those of us who are trying to run an honest business. Plus the fact that it will deter many people from getting into the direct selling business. The litigation reporting portion of the rule seems unfair and discriminatory to the direct selling business. It is unfair to not be able to distinguish between winning and losing lawsuits. In my mind even more unfair that it would have to be reported anyway. If most people knew about the volume and type of law suits for most of the companies they buy products from, I dare say it would have a devestating effect on many of our national companies and thus a devestating effect on our economy. Yet those companies are not required to "put it out front" of the buying public. Why is the direct selling industry being discriminated against? Earning claims. There will always be those "bad actors" that make false claims. But why penalize the great majority of us that do it right? This business, like many tradational jobs ,is about opportunity and and individuals willingness to work to determine what the earning potential is. It seems discriminatory to make the direct selling industry to keep the detailed records and do this kind of reporting. The section on references seems to fly in the face of HIPPA. There are many who , for what ever reason don't want others around them to know they are in the business. But we would be compeled to violate their privacy if we have to report th "10 nearest sales people". What kind of liability will you be imposing on a corporation and individuals if there is ID theft at the very least? Again I appreciate the FTC wanting to protect the consumer, but I see the legitimate companies doing just that. There are money back guarantees. In many cases more favorable than that of tradational businesses. The dierect selling companies provide valuable products and services to the public not to mention an important boost to our national economy and the economy of many families including mine. Our organazations like the Direct Selling Assoc. are always at work to correct any wrongs that may be done. I don't think these government imposed rules are going to do it better.