Business Opportunity Rule #522418-12561

Submission Number:
Don Mirgon
Initiative Name:
Business Opportunity Rule
To: Federal Trade Commission RE: Proposed Business Opportunity Rule, R511993 I am writing to voice my concern over the proposed rule change. While I agree there are issues that need to be addressed, and am glad to see the Commission is looking for ways to clean up the industry and applaud you for that, I don't believe this is the answer. Indeed, I feel this will have such a chilling effect on the whole industry, it may go away and along with it the hopes and dreams of millions of hardworking, taxpaying Americans will be destroyed. I do not believe that is the goal. The loss of tax revenues alone should cause people to re-think this approach. Over the last 20 years, I have been involved with a few Network Marketing opportunities. The knowledge, wisdom, patience, people skills and income I have received from these endeavors have added immeasurably to my life and to the attitudes of my now grown children. No doubt as they learned, they will teach, as they create the next generation of Americans. Without this industry, what outlet will they have? Congress passed laws to foster the growth of small home based businesses. The proposed rule changes will effectively shut mine down. Waiting period: I waited 14 days making up my own mind, doing my own research. Once I started, I was doing business that day. I have seen some of my associates do the same. Others were ready to start as soon as they saw the opportunity. All wanted their product immediately. Requiring an additional 7 day wait before ordering their product would have cast such a huge negative over the whole transaction; that it would not have happened. I myself would not have gone through with signing up. It would have signaled me of way too much governmental interference, which always lowers business productivity. References: I am quite satisfied with the references my company makes as to who they are and who they partner with. I do not want to know personal information about distributors, nor do I wish my information given out to anybody who wants it. I am a single man. Spreading such information about single women/moms is a recipe for disaster, what with all the predators running the streets. Earnings Claim Statements: I agree this is quite a tool when used by swindlers and a reasonable enforcement mechanism needs to be constructed and used. Perhaps the FTC can be the clearing-house for all such fantastic income claims, and a certificate of authenticity issued that is to become part of the distributor application. I am speaking of the top income earners, not every distributor. I believe the FTC still has credibility with the majority of Americans and this would give you the opportunity to scrutinize such claims first hand. Legal Actions: Perhaps a more accurate outcome would be to require all documented negative outcomes be reported when asked for. FTC could specify to format, and require registering with them for those few hucksters out there who want to straighten up and fly right. The liars will always lie, no matter what restrictions are put on them. Cancellations/Refunds: While this may interest some people, it will require a lot of action for the company, for very little return. I have yet in over 20 years in this industry ever had anyone ask me about this subject. In closing, I must say that if these rules were in effect when I looked at this business, I would not have gotten involved. I think like most middle income, blue collar Americans, and feel they won't get involved either. The rule change is un-necessarily burdensome. No matter what changes are made, there are always going to be a few people who will continue to try and make a dishonest dollar. DON'T PUNISH THE INNOCENT, PROSECUTE THE GUILTY Respectfully submitted, Don Mirgon