| Comment Number: | 522418-02321 |
| Received: | 6/15/2006 12:12:06 PM |
| Organization: | |
| Commenter: | Brandenburg |
| State: | TN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I appreciate the work of the FTC to protect consumers, but I believe as currently written the proposed Business Opportunity Rule is more burdensome than necessary to achieve that goal. I have been a Weekenders Independent Fashion Coordinator for three years. I am currently in the process of recruiting new coordinators with a personal goal of becoming a Team Leader. I do not understand why the usual three day right of cancellation is not sufficient. Requiring a seven day waiting period causes an unnecessary delay. Weekenders already has a 90% buyback policy for all products including sales kits purchased by a salesperson within the last twelve months. The proposed rule calls for the release of information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It is unfair that it does not distinguish between winning and losing lawsuits. It does not make sense that I would have to disclose these lawsuits unless Weekenders is found guilty. Of most concern to me is the proposed rule requiring the disclosure of a minimum of ten prior Coordinators nearest to the prospective Coordinator. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. In order to get the list of the ten prior Coordinators, I will need to send the address of the prospective Coordinator to Weekenders headquarters and then wait for the list. I also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a salesperson “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met. If adopted, this rule would have the consequence of delaying the prospective coordinator from starting business and earning income, as well as the time and expense to the company and the sponsor for information gathering and record keeping. Thank you for considering my comments.