| Comment Number: | 522418-02454 |
| Received: | 6/15/2006 9:31:48 PM |
| Organization: | Xango |
| Commenter: | Michael Bradshaw |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
The proposed rule changes for direct marketing business have both positive and negative impacts on me as a small at home business person. A few of the negative things regarding this proposal is first of all the $500 minimum investment for this franchise. Not only myself but the people I help and share my business with are simply not able to pay this kind of franchise fee. This type of business enables an average person to gain access to a large company and work hard then generate an above agerage income. I truly respect the views and considerations of the FTC and ask the same of you for me. The second point is the names of the 10 closest distributors in a given area. I feel this viololates my sense of security within my market and violates my sense of privacy. Seven-day waiting period: o Casts the direct selling plan in a negative light o Record keeping and administrative problems o Unnecessary delays o Impractical Elimination of the $500 business threshold: o Forces the majority of direct selling companies to comply with other provisions of the proposed rule that are more appropriate for businesses requiring a greater investment than a direct selling sales kit · Litigation Reporting: o Unfair in that it does not distinguish between winning and losing lawsuits o Irrelevance of the reporting of almost all litigation regardless of the outcome · Earnings Claims: o Difficult to collect required data o Targeted “bad actors” will not provide accurate data, while legitimate companies will · References: o Impracticality of finding the “10 nearest existing sales people” o Privacy and safety issues o Possible corporate liability for ID theft Thank you for your consideration in this matter and please don't hesitate to call or mail me with any questions or concerns. Thanks again, Michael Bradshaw