Business Opportunity Rule #535221-00100

Submission Number:
Jon Taylor
CONSUMER AWARENESS INSTITUTE - and JON TAYLOR & CO. - and advisor, Pyramid Scheme Alert
Initiative Name:
Business Opportunity Rule
I am pleased to rebut some of the many misrepresentations presented in the comments by Primerica Financial Services (#535221-00056). First let me express my outrage that Timothy Muris, who once chaired the FTC, is now on the other side of consumer protection – writing for the very type of company he should have been regulating for the protection of consumers. And what about J. Howard Beales, who once worked with him in enforcement functions? Is whatever they are being paid worth shifting from consumer protection to fraud protection? Or do they not know the difference between the two? Whatever their motivation, consumers are in for a rough ride with this kind of influence peddling. These comments reflect many of the comments made by the DSA, so the attached rebuttal comments (#535221-00091) would apply to those. As for their proposed wording of RPBOR, since us consumer advocates totally oppose a Business Opportunity Rule that exempts MLM, the wording is irrelevant. Primerica and other DSA members are merely trying to make certain these MLM/pyramid/chain selling companies are fully protected. Their mantra – up with MLM fraud – screw consumers! FTC officials: Please ignore all language proposals initiated by Primerica and their ilk and set aside the Rule altogether, rather than adopting a Rule which exempts the most fraudulent “business opportunities” the world has ever seen from having to disclose information essential to consumer protection. Respectfully submitted, Jon M. Taylor, MBA, Ph.D., Pres. CONSUMER AWARENESS INSTITUTE, and Pres., Jon Taylor & Co., 291 E. 1850 South, Bountiful, UT 84010. Email: