| Comment Number: | 522418-00583 |
| Received: | 6/2/2006 7:30:42 PM |
| Organization: | Financial Freedom Builder, LLC |
| Commenter: | Allen Booher |
| State: | UT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam, I am including the sample letter language suggested by Synergy Worldwide and the Direct Selling Association, because it is adequate although far too diplomatic. This paragraph is my own thoughts. In my opinion, the FTC is absolutely "off-base" in its attempts to protect citizens from business opportunities. Let's face it. Adult American citizens are intelligent enough to work, pay taxes, decide to smoke or not, gamble, participate in gifting clubs, skinny dip, etc. Hey, I've done stupid things with my money from time to time and it is my right and privilege to learn from my mistakes. I have spent the last five years creating the business-building methods that comprise the Financial Freedom Builder System. I am about ready to launch my business with very little capital. Your proposed rule will kill my business and my hoped for end-result of helping many people achieve complete financial and time freedom through a very legitimate company called Synergy Worldwide. I do not support any further efforts to police the network marketing or multi-level marketing industry. In fact, I'd rather see the FTC just leave the industry alone and let it mature as did the franchise industry years ago that now accounts for a large portion of GDP. I have done extensive research to ensure that I comply with the laws of the land in my business, but opportunity seekers must have the right to make their own decisions. By the way, the government sponsors the biggest pyramid scheme of all--Social Security and all other schemes whereby new entrants pay for the benefits of earlier entrants. So, let me make myself clear. If the FTC passes this rule, I intend to get political fast. You can be assured that I will not stop until the FTC is reigned in to a great degree. Now, you can read the nice letter below that was drafted for me, but which I totally agree with. I am writing this letter because I am concerned that if the proposed Business Opportunity Rule R511993 is adopted in its present form, my livelihood as a Synergy WorldWide distributor will be significantly undermined. The very thought of governmental interference in the free enterprise process strikes fear in the hearts of Americans everywhere. Cherished values are at stake, and the FTC needs to be aware of the dangers of ill-considered action. The public is not well served by the FTC’s over regulation of an industry that is causing absolutely no harm and more than adequately polices itself by remedying any and all complaints by members of the public. Synergy WorldWide complies with all applicable buy-back requirements and always makes it easy for individuals to exit the Company, if the business opportunity is not right for them. While the FTC needs to protect the public where necessary, this proposed rule is hopelessly overbroad and misguided. The seven-day waiting period is unnecessary and will interfere with my ability to enter into lawful transactions and enroll new distributors. People buy TVs, cars, and other much more costly items without such a waiting period. This proposed waiting period gives the impression that something is wrong with the plan. And, the burdensome paperwork, which will not even be read by the public, makes it extremely difficult for the individual participant to fully comply, thereby risking fines and other penalties for such failures, however innocent. By these actions, the FTC does a disservice to the consuming public and Americans everywhere who are trying to get ahead by starting their own business, or adding necessary supplemental income to their family. While I appreciate the work of the FTC to protect consumers, I believe this proposed new rule has many unintended consequences that could be avoided by a less burdensome approach. Thank you for your time in considering my comments. Sincerely yours, Allen Neal Booher