Comment Number: 522418-01742
Received: 6/11/2006 12:03:49 AM
Organization:
Commenter: Bill Howard
State: AZ
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing to express my concern about the proposed Business Opportunity Rule,R511993. As a former Legislator in a leadership position I appreciate and agree with your goal and the need to deal with fraudulent groups and unscrupulous individuals. Unfortunately in our attempt to catch a small number of offenders we often find that our rule or bill was far more far reaching than intended and the conseqences end up hurting the legitimate groups and individuals which comprise the vast majority. Here are the problems I see with the rule as presently proposed: 1.Many families supplement their income by having a home based direct selling business while at the same time allowing one or both parents to be home with their children. 2.The legitimate Direct Selling Companies provide extensive on going training to their people to help develope confidence, skills and education in ethical behavior and compliance with existing rules and regulations. 3.A seven day waiting period would be extremely harmful. It would send the wrong message to anyone considering going into a direct selling business.It would cause unnecesary delays as well as creat additional record keeping and administrative problems. It would pose the question-other businesses don't have this type of waiting period, what's wrong with this business that reguires such a wait? 4.Being required to report ANY information regarding lawsuits would do a real injustice to companies found innocent in a lawsuit. Unfortunatly we live in a very litigous society.People can file a lawsuit for almost any reason.Only the guilty should be disclosed NOT the innocent. 5.I graduated from college in 1951 and have been dealing with the public in one way or other since then. I can not imagine being in a busines that would reguire me to disclose one(1) let alone ten(10) or more prior purchasers that I had done business with. That is strictly confidential and would be a violation of trust to my client(s) without their permission.References -certainly, but with privacy issues and identity theft disclosing my clients -No. 6.I am confident that there are currently more than enough laws and rules and regulations available to deal with the type of group or person(s) that is the focus of this proposed rule without adding yet another rule. I truly appreciate the work that the FTC does to protect me ,a consumer ,but I believe this proposed rule, if implemented, will do irrepairable harm to the legitimate Direct Selling Companies and their organizations which comprise tens of thousands of hard working Americans who are worling long hours each day to provide a better life for their families and friends. Just the mere mention of the possibility of the contents of this proposed rule becoming the law has already caused the stock of many publicly traded Direct Selling Companies to suffer severe drops in value hurting thousands of investors and wiping out the savings of many of those who will be hurt the most by these rules. Thank you for giving me an opportunity to express my thoughts on this very serious matter. Bill Howard