Comment Number: 522418-11179
Received: 7/17/2006 6:24:30 AM
Organization: Xango
Commenter: William Farr
State: CO
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am relatively new to the MLM business. I have been a Xango distributor for just under one year. I staarted in this business as a way to supplement my income and help my family. This business appealled to me because it was so easy to start and run and the investment required was very small. I recently found out about this proposed rule and I am very concerned about it's effect on my new business. I don't pretend to know all the problems that you are attempting to solve I am sure that there are many of them in this industry. As a law enforcement officer myself I can appriciate that there is a lot of fraud in all aspects of life and especially in business. I have seen some things in this rule that will cause serious problems for those of us who are trying to conduct an honest business. The first problem I have seen with this new rule is the elimination of the $500.00 threshold. When I sign up a new distributor thier total minimum investment is a $35.00 distributor kit. Requiring everyone to become a franchise will cause them more paperwork and will make this business more complicated than it needs to be. This will also close this business to the average person like myself who does not want to be involved in an intricate business venture. The next problem is finding the nearest 10 existing sales people. This is very difficult to do as none of them may be part of my organization. We have thousands of people signing people up from all over the world daily. I would not be able to find these people. If I could find these people I don't think it is fair or safe for me to give out thier information to anyone. I also believe that the seven day waiting period will hurt my business because of the negative light it will shed on it. When I tell people that they are not allowed to join my business until seven days after I give them all the disclosures it will make them unnecissarily suspicous of the business. Considering the intitial investment in Xango and many other companies is so small, I believe this period is not needed. I am sure that you have had several comments sent from my industry and I thank you for listening to them and to mine. Please understand that many of us got into this industry because it gives us average people a chance to supplement our income on a part time basis with very little complication. The MLM industry is full of housewives, single parents and people with families who are trying to get ahead. The addition of this significant rule will cut the average person out of this business and have a major impact on us. I urge you to rethink this. Bill Farr