| Comment Number: | 522418-02911 |
| Received: | 6/16/2006 4:47:39 PM |
| Organization: | Independent Distributor for Xango, LLC |
| Commenter: | Shirley Rust |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
These comments are in reference to Business Opportunity Rule R511993 My husband and I are currently engaged in the Direct Marketing business. You are probably aware that this is a viable and legitimate form of business. We are 60 years old and have been in the direct marketing business for the last 9 months. We are looking to this business to help us through our retirement. My husband and I are not healthy and will soon not be able to keep up with the day to day grind of holding down a job consisting of physical labor. Although we have two children they are not in a position to help us financially when we retire. Therefore, direct marketing perfectly fills our needs. We appreciate the effort and intent of the FTC in this matter. It is only a foolish person who cannot see the problems that exist with unscrupulous business persons and scam artists. The work you are doing and the protection you provide is much appreciated. While we understand why you are proposing this rule we feel it would be damaging to our business. I feel that the best interests of the American public in this crucial area could best be served in other ways. There are 2 specific areas of concern that we have with this proposed rule; 1. The 7 day waiting period creates a great inconvenience to us as well as to those who are anxious to participate in the business opportunity...it also makes us look suspicious to those who are considering the opportunity. This rule alone I feel would almost bring our business to a halt. Our business opportunity requires only a small financial investment ($35) and it offers a generous, guaranteed buy back policy, For many of those in our industry this rule will cause unnecessary delays, administrative problems, and is impractical for us to deal with. 2. The list of nearest references rule... Since we are not acquainted with all the distributors and users of the product this will mean added delays to those who want to get started as a distributor or a user of the product since I willl have to contact Xango (tm) headquarters for a list of contacts in a particular area. Our business is already in 3 states and we are working on cultivating other areas. This rule would be devastating, awkward, and time consuming. There are also privacy issues connected with this portion of the rule. ID theft is becoming one of the biggest criminal activities in the US and there are lots of individuals, including myself, who would not like their personal information floating around for anyone who cared to take a look at it. This would be a haven for not only ID thieves but also for our competition to get a hold of. Whereas these rules will really not have a significant deterrant effect on the criminals you are trying to impact they will have a devastating effect on those of us who are honest business persons trying to comply. Please reconsider what burdens and problems you will be creating for the honest and legitimate direct marketing business person. Thank you for your consideration and allowing us to comment on this issue. Sincerely, Ken and Shirley Rust