| Comment Number: | 522418-03025 |
| Received: | 6/16/2006 10:02:53 PM |
| Organization: | Xango LLC |
| Commenter: | William Rodgers |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I would like to comment on your Business Opportunity Rule #R511993 that is currently under condersideration. Althought I support your effort to address fraudulent activities in the direct sales industries, This perticular proposed rule change would have some serious negative effects on legitimate direct sales distributors such as myself. For example the requirement to list slaes nearest the location to the prospective new distributor would not only be very difficult, but very time consumming and would jepordize the recruitment of new distributors to my net work. This is also true of the 10 day wait period. In the case of Xango, they have been very honest and straight forward in representing their product and business opportunity with procedures in place to identify and weed out anyone who makes false claims about their product or compensation plan. Since much of our industry relies on enthusasium generated from product results any delay in getting people started would greatly affect the success of growing my distributor business. I wish to urge you to be very careful in your pursuit of eliminating fraud and misrepresentation and not penalize the ligimate companies that bring a great service to their customers and their independent distributors. When managed properly the MLM method of marketing provides an excellent business opportunity for the independent distributor and eliminates the problems associated with big Corporate sales business. In the case of Xango, they have done an outstanding job in bring their product to the market and making it avaliable to the public. Please make sure your new business rule does not distroy a company like Xango and other like companies by inacting rules that will delay and have a negative inpact on recuriting their independent sales distributor base. Since they depend on independent distributors like me to build this base, your rules will greatly affect me and others like me. So please do not pentalize me for the fraudulant business practices of others.