|Received:||6/16/2006 8:14:57 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been working in the network marketing business model for many years now. I was introduced by an acquaintance and I learned a lot from him. This business has not yet proven a substantial income, however Xango is the first company which has given me more than one paycheck and I am poised to increase my earnings dramatically over the coming months. IF you don’t impose these unreasonable rules that is! Direct sales helps me to build my network, use my relational skills, and do something positive for the community by distributing a product which is helping people’s health around the world. I enjoy the freedom and incentive that working for myself offers. I appreciate that you want to look out for the consumer’s interest by making laws which guard against scams. There are many out there, but Xango is NOT one of them. I wonder if maybe some corrupt/ greedy pharmaceutical company or companies are behind this? As history shows through allegations against Herbalife and others, when competition arises the sharks come to prey. Major Problems: The 7 day waiting period puts the direct selling model in a bad light. It can lead to record keeping and administrative issues, unnecessary delays, and it’s just not practical. The $500 business threshold rule is ok for other businesses which have a higher up front investment, but not ours. The earnings claims make it difficult to collect the needed files. Requiring people to locate the “10 nearest existing sales people” is an outrageous claim. This is completely unjustifiable. It can lead to privacy and safety issues as well as inconvenience for all parties involved. It’s also a potential corporate liability for identity theft.