Business Opportunity Rule #535221-00001

Submission Number:
Reid Parrington
CT Dept. of Consumer Protection/ Public Charities Unit
Initiative Name:
Business Opportunity Rule
As a lawyer in the public sector in the consumer protection field I am dismayed and disheartened by the FTC’s decision to drop the MLM (pyramid scheme) industry from this proposed rule. The literature on the subject overwhelmingly establishes that this “industry” is based almost entirely on unfair and deceptive practices. In sum almost all MLM promoters lie to prospective “distributors” about the nature of the products/services they sell, the efficacy of the business model they promote and the actual money making histories of the other “distributors”. All that the proposed rule would require is the MLM peddlers tell some of the truth about their businesses to persons who have a need to know and a right to these facts and who are not in a position to get the facts elsewhere. These disclosures would cost the MLM promoters little (in actual cash outlay, that is) and the public purse nothing. The MLM industry is based on two principles: 1. “There’s a sucker born every minute.” and 2. “Never give a sucker an even break.” I expect more from my fellow public servants and urgently ask the FTC to reconsider its dropping of the MLM “industry” from the proposed rule. (n.b. These are my personal views and do not reflect any position or policy of the Connecticut Dept. of Consumer Protection)