| Comment Number: | 522418-00046 |
| Received: | 5/16/2006 10:51:23 AM |
| Organization: | |
| Commenter: | Dawn Meland |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Please HALT the FTC rulemaking Process that will drastically inhibit our precious domestic freedom to participate in direct selling opportunities! This change is inadvertently or deliberately designed to dampen the enthusiasm of new prospects considering multilevel business opportunities. It will have a devastating impact on the entire direct selling industry. It will smother millions of good-faith Americans with paperwork and records who are making a living as multilevel distributors. While it may have made good sense to require a 7 or 10 day waiting period before a person invested and risked thousands or millions of dollars in a Holiday Inn, McDonalds or Sports franchise, it makes very little sense to require a very small multi-level business person to have a mandatory 7 day waiting period before signing up another distributor if the cost is usually much less than $500. It would be a far more reasonable proposal if the FTC’s rule exempted all business opportunities costing less than $500. The FTC would have a hard time to defend a rule that required all persons buying furniture, appliances or automobiles costing hundreds or thousands of dollars to wait 7 days. Yet, without blushing, the FTC now proposes a rule that would require all persons to wait 7 days before signing up as multilevel distributors. The cost is usually far less than $500. For about 25 years the FTC’s Franchise Rule covered only those opportunities that required a buyer to make a payment of at least $500 within the first six months of operation. The April 12 2006 proposed Rule completely eliminates this $500 exemption! In 1979, to justify the reasonable $500 exemption, the FTC wisely said: “When the required investment to purchase a business opportunity is comparatively small, prospective purchasers face a relatively small financial risk. Please re-think this change and keep the $500.00 exemption rule in place.