| Comment Number: | 522418-02525 |
| Received: | 6/16/2006 1:44:59 AM |
| Organization: | |
| Commenter: | Shawber |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been in business since 1983 and was introduced by a woman who received our name through Welcome Wagon. We answered her flyer to purchase products that helped keep our children's clothing look new for years. I got into the direct sales business by viewing the opportunity in her home and began signing up friends. The next few months were critical and I quickly sponsored three with 9 others to follow. I was able to maintain cash flow and our home while laid off twice from my professional management career in the metals business by building my direct sales business. It has added significantly to my esteem, confidence and position in soceity. We are grateful that the FTC is working to protect us, however please do not create undo regulations on our business that will prevent rapid growth of our new distributors. We know there are fraudulent groups, however some of the rules being considered unfairly target our legitimate direct selling business. For example: 7-day waiting period unfairly casts the direct selling plan in a negative way. The record keeping and administration will create unprofitable work requirements. Plus, it causes unnessary delays and is simply impractical. The elimination of the $500 business threshold forces the majority of direct selling companies to comply with other provisions that are more appropriate for businesses requiring a greater investment than a selling sales kit. The litigation reporting is unfair in that it does not distinguish between winning and losing lawsuits. And the irrelevance of the reporting of almost all litigation regardless of the outcome. Earnings claims are difficult to collect required data. It also targets "bad actors" and will not provide accurate data, while legitimate companies like ours will. References are impractical as finding the 10 nearest existing sales people causes privacy and safety issues and may be targest for possible corporate liability for identity theft. This business is very important for many people, including my family, so please reconsider the proposed rules and do not put them in place for this industry. Regards, Mr. Shawber