| Comment Number: | 522418-02348 |
| Received: | 6/15/2006 1:36:41 PM |
| Organization: | Xango |
| Commenter: | Allison Delzell |
| State: | IA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: Business Opporitunity Rule, R511993 To whom it may concern: I have just become an independent xango distributer and am dissapointed to hear that my opportunity for income may be affected. I have a 1 1/2 year old daughter and am trying to provide for her by working from home so that I can be with her. I have never been on any government programs and would like to continue to be self-supporting. I am just trying to work hard and honestly and would ask that it is not unduly complicated. I want to continue to be a stay at home mom and provide for all the needs of my daughter. I appreciate that our government wants to protect us from unscrupulous individuals, but I would ask them to keep in mind that the laws must be very well thought out because the ones who will abide by them are the honest people and not the criminals. They will simply find more ways around them while the honest individuals are obeying a whole new set of rules. In short the proposed seven day waiting plan casts the direct selling plan in a negative light while diminishing natural enthusiasm to get started, it will cause record keeping and administrative problems, also it is the source of unnecessary delays and is impractical. The elimination of the $500 business threshold forces the majority of direct selling companies to comply with other provisions of the proposed rule that are more appropriate for business requiring greater investment and therefore greater risk and potentially greater loss than a direct sales kit. The litigation reporting is unfair because it does not distinguish between winning and losing lawsuits, and is irrelevant because of the need to report almost all litigation regardless of the outcome. The earnings claim is also an unnnecessary burden because it would be difficult to collect the required data and the targeted group will not provide accurate data while legitimate companies will. And lastly, the it is impractical to expect people to be able to constantly be aware of the "10 nearest existing sales people". Those that travel a lot would find much time consumed in constantly finding the 10 closest. And also it creates privacy and safety issues in that anyone who was in my area would be able to hand out my name and contact information to anyone they chose whether they were going to pursue the business or were just checking it out. It would also create the possibility for coporate liability for ID theft since someone would have to maintain the database with all the information and re-distribute it. I am just asking that you truly consider the possible negative impacts on the legitimate and hard working companies and individuals before putting anything into action. Thank you for your time.