Business Opportunity Rule #535221-00096

Submission Number:
535221-00096
Commenter:
Jon Taylor
Organization:
CONSUMER AWARENESS INSTITUTE - and JON TAYLOR & CO. - and advisor, Pyramid Scheme Alert
State:
UT
Initiative Name:
Business Opportunity Rule

Not surprisingly, in Comment #535221-00075, Peter Mingils and Marcie Cook of the MLM DRA, which represents a much smaller number of member firms than the DSA, is supportive of the FTC’s move to exempt MLM companies from the RPBOR. Those of us who donate our time advocating for consumers could not disagree more on the objectives of the MLM industry on this FTC Rulemaking issue. It would be difficult to find an issue more central to consumer protection than doing everything possible to stop them in their onward march towards complete corruption of the direct selling marketplace. Mingils and Cook “Due to the fact the Revised Proposal is written in a narrative format we reserve the right of final approval until the final written rule is formatted as it will be implemented.” I would assume that such concession would also be made to those of us advocating for consumers – and that we get precedence, since the mission of the FTC is to protect consumers, not recruiting MLMs (that depend on sales to recruits for revenues), or product-based pyramid schemes, presently or potentially defrauding them. The same is true of any formal or informal conference – consumer groups have as much or more right to be represented as MLMs. I am in a unique position to comment on the MLM/Network marketing industry the MLM DRA attempts to represent. Having over 40 years experience in entrepreneurship, legitimate direct selling, sales training, small business consulting, and teaching entrepreneurship as an adjunct instructor, I know the difference between legitimate direct selling and programs that feature an endless chain of recruitment of participants as primary customers. In law enforcement, the demands of MLM companies are typically in direct opposition to the interests of consumers who need protection by the FTC from product-based pyramid schemes masking as supposedly legitimate “MLM/direct selling companies”. Please read the attached rebuttal of DSA comments in my comment #535221-00091. Respectfully submitted, Jon M. Taylor, MBA, Ph.D., Pres. CONSUMER AWARENESS INSTITUTE, and Pres., Jon Taylor & Co., 291 E. 1850 South, Bountiful, UT 84010. Email: jonmtaylor@juno.com