Business Opportunity Rule #522418-11172

Submission Number:
Birgit Pearson
Initiative Name:
Business Opportunity Rule
RE: Business Opportunity Rule R511993 To Whom It May Concern: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it would prevent me from continuing as a XanGo, LLC independent distributor, and would destroy the small business I have worked so hard to build. I became an independent contractor representing XanGo, LLC, four months ago. Originally, I started Network Marketing because I loved the product and wanted to earn additional money. I depends on this extra income to supplement my SS. Please don't destroy my small business, we need it. Some of the sections in the proposed rule (Rule 511993) would make it hard, if not impossible for me to sell the XanGo and make it difficult to introduce others to this fantastic opportunity. Changing to the new rules would devastate the growth and profit potential of the business I operate. 1. Seven day waiting period: The proposed waiting period will give the public the idea that there's something wrong with the XanGo business plan and also will reflect badly on me. I believe this seven-day waiting period is unnecessary, because XanGo already has a 90% buyback policy for products including the sales kit purchased by a new representative. The Xango sales kit only costs $35.00. The current procedures in place by XanGo already insure that no one can ever be hurt financially by the XanGo business opportunity. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone (a prospect) and will then have to send reports to my company. I am a small home business and this burden could destroy my company. 2. List of nearest references. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval). Women in my organization may be subject to sexual or racial harassment so this part can't go in at all, unless the FTC passes an addition to this rule prohibiting sexual or racial attacks related to this disclosure. In the end the rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. 3. Earnings claim statement. The proposed rule requires potentially complex compilations of statistical matrices of time periods, demographic data and earnings claims. While I strongly support the proposition this requirement will not deter fraud. A fraudulent company will not provide accurate data, while legitimate business sellers will have difficulty in meeting the proposed requirements. 4. Legal actions: This rule requires disclosure of litigation potentially unrelated to the business opportunity transaction, but it doesn't provide for disclosure of the outcome of the litigation. At the very least this requirement should be modified to take into account these problematic elements. I have seen many scams on the Internet and been approached by crooks. This rule will not stop Crooks - they violate the current rule all the time. This hurt my business! The proposed rule would make it extremely difficult to build and operate my XanGo business. I am a good American citizen and this rule will hurt me. Sincerely, Birgit Pearson