Business Opportunity Rule #535221-00006

Submission Number:
Jon Taylor
Initiative Name:
Business Opportunity Rule
ATTN: FTC officials: Please read carefully the attached comments regarding the Revised Business Opportunity Rule. Also, my comments submitted as rebuttals to the original Rule are a summary of thousands of pages of research and feedback from all over the world. So I would suggest you read those again as well. In the attached comments, together with information on my web site ( I have provided good evidence to suggest the wisdom of scrapping any revised Business Opportunity Rule that exempts MLM (multi-level marketing) from compliance with the Rule. Such an exemption would only serve to encourage MLM promoters to continue even more blatant fraud against consumers who may be considering any MLM program that depends for its very existence on a complex set of deceptions to survive and grow. And as explained, replacing meaningful disclosure with the use of Section 5 is not a step forward. Section 5 has been used only very sparingly in such cases, and the FTC does not have the manpower or other resources to investigate the hundreds of fraudulent MLMs we have observed. A rule requiring meaningful disclosure for all MLMs would be much more cost effective and realistic. I understand the enormous pressure placed upon you by the DSA, its member firms, and Congressmen who are beholden to them. But the very integrity of our free market system is at stake, to say nothing of the financial well-being of millions of people who are struggling to find some way to supplement their income – without being ripped off by one of the hundreds of MLM/pyramid or chain selling schemes that are actively recruiting. No rule, is better than a bad rule - or a rule that leads consumers to believe they have some protection, when in fact they are left exposed to the worst schemes. The FTC has a mission to prevent fraud, deception, and unfair business practices in the marketplace. A Business Opportunity Rule that exempts MLM is an abrogation of that mission. It would be far better to scrap the Rule altogether, and start afresh when a consumer friendly (as opposed to anti-regulatory) political climate that allows you enact a rule consistent with the FTC's mission. Sincerely, Jon M. Taylor, MBA, Ph.D., President, Consumer Awareness Institute, and Advisor, Pyramid Scheme Alert