Consumer Awareness Institute
Trade Regulation Rule on Disclosure Requirements and Prohibitions Concerning Business Opportunities - FTC File No. R511993
RE: Serious problems with the latest staff report – especially in the light of new information – and a $10,000 challenge, Part 4 From the staff report we read: " . . . the IPBOR would have unintentionally swept in numerous commercial arrangements where there is little or no evidence that fraud is occurring." (page 30) "None of the comments received provided an industry-wide analysis of pyramid schemes masquerading as MLMs. They ask the Commission to assume widespread fraud in the multi-level marketing industry, but offer no evidence." (Footnote 60 on Page 21) Referring to Part 1 of my comments, the above quotes are found to be totally false, not only from the research reported in Chapter 7, but also from what I previously submitted (referring to 30 misrepresentations posted on my web site) - and now over 100 misrepresentations, as listed in Chapter 8 of my e-book, which is attached. Also included in Chapter 8 are specific misrepresentations made by the 30 MLMs included in the study on loss rates reported in Chapter 7 – most of them relating to false earnings claims. Keep in mind that a company with a 99.6% loss rate is misrepresenting the offering by even suggesting that it is an income or business opportunity – without at the same time disclosing that almost everyone – except for a few at the top – lose money. New recruits are being sold a ticket on a flight that has already left the ground. So again I refer to my $10,000 challenge: Identify any business opportunity that is more unfair and deceptive, and viral and predatory as well, and you can collect $10,000 (drawn from my limited personal retirement funds) or name your favorite charity to receive it. See the Appendix in Part 1 of my comment submissions for details.