| Comment Number: | 522418-02936 |
| Received: | 6/16/2006 5:39:49 PM |
| Organization: | |
| Commenter: | Robert Levy |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My name is Robert Levy. I am an Independent Associate of Pre-Paid Legal Services, Inc., and I am writing today about the FTC's proposed "Business Opportunity Rule R511993". I have been with Pre-Paid Legal for nearly eight years. I am greatly concerned because I believe this rule would have a negative impact on my home-based business, my income and my family. The FTC would require a seven-day waiting period before new Associates can sign up as a Pre-Paid Legal sales Associate. The FTC would require me to provide the names and telephone numbers of the 10 nearest prior purchasers of the "Business Opportunity" to all potential Associates. This disclosure will violate the privacy rights of other purchasers, and create opportunities for identity theft. The FTC would require me to provide a list of lawsuits filed against the company going back 10 years. This is unfair because it does not distinguish between findings and allegations. Since people file lawsuits for all sorts of reasons, and sometimes for NO reasons, requiring this kind of disclosure effectively allows meritless lawsuits to turn into winning lawsuits. While the FTC's proposal might be well-intentioned, I believe it is ill-conceived and would have a dramatic negative impact on many or most small businesses. It would unfairly target legitimate, publicly held, direct selling businesses like Pre-Paid Legal Services, Inc. While I understand and agree that there are corrupt "opportunities" popping up virtually everywhere, this is not the way to deal with them. It is punitive to those of us with integrity and vision, who promote doing the right thing. That is integral to our training! It is said that time will either promote you or expose you; Pre-Paid Legal Services, Inc. is a rock solid, NYSE company with over 33 years of experience! I respectfully request that you STOP this proposed rule! Sincerely, Robert Levy