Business Opportunity Rule #535221-00020

Submission Number:
Paul Byrne
Smart Circle International
Initiative Name:
Business Opportunity Rule
First, I would like to express appreciation for the FTC's efforts to consider the views of thousands of direct sellers and concur with the FTC’s conclusion that revisions to the originally proposed rule were necessary to exempt legitimate direct sellers from coverage. As a direct selling company and member of the Direct Selling Association, I recognize and support the FTC’s important consumer protection role and share the commitment to protecting the public from unfair and deceptive business practices that undermine consumer confidence in legitimate business enterprises such as our own. I just want you to know that our company fully concurs with the comments and suggestions submitted to the FTC by the Direct Selling Association, and trust that these helpful recommendations will be incorporated as the FTC works to perfect, clarify, and implement the improved and revised business opportunity rule. Sincerely, Paul Byrne