Business Opportunity Rule #535221-00079

Submission Number:
Reid Parrington
Public Charities Unit
Initiative Name:
Business Opportunity Rule
Secretary Clark, I am responding in rebuttal to the comment of Ms. Frances Avrett #535221-0046. I chose her comment for rebuttal by selecting the first comment on the list sent in to the FTC by an actual MLM participant. Her’s was the first, in alphabetical order on the list and I needed to go no further to find what I am sure you will agree is a typical comment sent in by persons in her situation. I quote: “I have been a representative with Primerica for 27 years. Primerica has provided me the opportunity to have my own business and to support my family’s needs and dreams. In volatile economic times such as now, legitimate business opportunities, such as Primerica, provide individuals like me with an opportunity to work without fear of losing my job and to increase my income when so many people are taking pay cuts just to stay employed.” Please note the vague and generic tone of this comment especially the “needs and dreams” reference. Can’t you see that Ms. Avrett is not a “business owner” and certainly not a “legitimate direct seller”? Note, that she does not say “ the past 27 years I have made net profits of $______ selling XYZ. Inc.’s fine products/services to a loyal and growing clientele of retail customers…” What Ms. Avrett almost certainly is is a consumer. A consumer of “dreams”. One wonders how much she has spent over those years on the “dreams” sold to her by this, and perhaps other, MLMs. If the FTC were to take a good look at the comments sent in by actual MLM participants I am sure that you will find a lot of references to “hopes”, “dreams”, “family” and “fear”, and very little nuts and bolts facts about actual business operations…you know…actually making real, net, money. Letting MLMs off the hook in the revised rule would be a real disservice to America’s consumers. Better no rule than a flawed one. (Please note: these are my own views, not necessarily those of my employer.)