|Received:||7/17/2006 12:45:50 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am a distributor for Xango. I have just gotton into this business. Direct selling is good for me to earn extra income for my family. I appreciate your consumer protection intentions but I am concerned for its impact on legitimate direct selling companies. I know there are some fraudulent groups out there, but this particular rule infairly targets direct selling businesses. Seven day waiting period casts the direct selling plan in a negative light and will cause unnecessary delays. It will also cause record keeping and administrative problems. Elimination of the $500.00 business threshold forces the majority of direct selling companies to comply with other provisions of the proposed rule that are more appropriate for businesses requiring a greater investment than a direct selling sales tax. Litigation reporting will be unfair in that it does not distinguish between winning and losing lawsuits and irrelevance of the reporting of almost all litigation regardless of the outcome. Earning claims would be difficult to collect required data, targeted "bad actor" will not provide accurate data, while legitimate companies will. References would cause impracticality of finding the "10 nearest existing sales people", privacy and safety issues and possible corporate liability for ID theft.