|Received:||7/17/2006 10:36:57 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Subject Category: Business Opportunity Rule CFR Citation: 16 CFR Part 437... I was introduced to Direct Sales in 2001. This particular business was very expensive for someone looking to make a little extra to stretch their corporate dollar. I was not given the facts up front and after many hours of learning by OJT I lost my qualifying status and needed to start over...in stead, I quit. But this type of business had a strong appeal because success did not have a ceiling...all I needed was give it 'my all'. After 35 years in corporate employment, I took early retirement in 2005 as opposed to a layoff and launched 2 direct sales businesses. I did my homework and basically began to train myself for a new career in direct sales. I understand the value in protecting the public and to undertake such a task is daunting. I am grateful to have the FTC doing that job. I ask that the FTC try to step back to realize that most individuals are not prepared or skilled in maintaining records...just look at the IRS Income Tax Return audits. Maintaining data to support 'references' and 'earning claims' requires a computerized database. The average person getting involved in direct sales generally does not know where to begin with automation. The automated tools such as a database is generally too complex and too costly to purchase or develop even with the skills. You would have to rely on the company to have such tools and that immediately reduces the bonus and commission funding that would otherwise come to the distributors. There are direct sales companies that pay commission within 7 days of signing a prospective distributor. This creates a strong sense of achievement for a new distributor and gives the prospect a level of excitement and enthusiasm that they have found a product/service and company that is truly committed to the distributors efforts. A 7 day waiting period would not support that value. Corporations constantly make their employees wait for company bottom line improvements before granting any pay incentive, if ever. I ask that you reconsider the wording of this Rulemaking and try to obtain information from those individuals in Direct Sales rather than using the abusive corporate model that has stiffled so many American entreprenuer spirits that are trapped in the corporate prisons.