| Comment Number: | 522418-03066 |
| Received: | 6/17/2006 1:39:22 AM |
| Organization: | Silver Kirin Entrprises |
| Commenter: | Danielle Schasse |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Greetings, I am writing this letter due to concerns regarding the proposed Business Opportunity Rule, R511993. In its present form, the proposed law would place additional burdens on direct-sellers. Implementation would undermine abilities to effectively run direct selling business, damaging my personal achievements and success as a Synergy WorldWide distributor. Our country is founded on the concepts of free enterprise and the economy depends on Capitalistic principles. The rights of entrepreneurs should not be jeopardized by governmental interference. It is critical that the FTC has full knowledge of the negative impacts that would develop from adopting this rule. The Direct Sales Industry is an enormous benefit to our economy and environmental conservation. As a Synergy WorldWide distributor, I work from home, creating less pollution, traffic, and gasoline consumption. When I first started direct sales, I was in serious debt and below the poverty level. Over the last few years not only have I paid off my student loans and other credit bearing accounts, I am able to pay my taxes each year. I help educate my neighbors, associates, friends, and relatives on healthful living, strengthening my community. As a direct seller, I am able to supply the demand of my customers directly, enabling them to do the same. A greater percentage of people are able to work for themselves, achieving the means necessary to live a desirable lifestyle and still maintain a strong and happy household. Over regulating this industry would detrimentally affect the public significantly, taking away from developing trends which promote quality values and living a balanced healthy lifestyle. Furthermore, the focus is on self regulation, adequately controlling the business by remedying any and all complaints by members of the public. Synergy WorldWide complies with all applicable buy-back requirements, provides full product guarantees, and permits individuals to withdraw if the business opportunity is not right for them. I appreciate the efforts of the FTC to protect the public; however, the proposed rule is ill-advised, poorly drafted, and overall unwise. The seven-day waiting period is unnecessary and will interfere with the ability to enter into lawful transactions and enroll new distributors. The majority of purchased goods in our market place exist without such a waiting period, why should direct product sales be an exception? The proposed waiting period may create the impression something is wrong with the plan, increasing uncertainty about possible undisclosed liabilities. This diminishes the potential of my business, threatening future income potential for myself along with thousands of other distributors in my up-line. Imposing restrictive requirements demanding unrealistic record keeping, excessive delays and administrative problems, litigation reporting with potential frivolous lawsuits. Moreover, requiring additional paperwork puts undue burdens on my ability to fully comply, thereby risking fines and other penalties for blameless actions. The lack of distinction between winning and losing, privacy issues due to ID theft and safety, is not aligned with good faith business practices. The FTC would cause a disservice to the consuming public and Americans everywhere who have the necessity to create financial stability. Starting their own business or supplementing their income can be accomplished with direct sales, without costly loans or increased risk. I have the utmost respect for the FTC’s objectives in protecting consumers, and I understand there may be fraudulent groups out there; yet the FTC’s proposed rule would unfairly target legitimate direct selling businesses. I believe there are considerable unintended consequences which can be avoided with a less burdensome approach. Thank you for your time, I truly hope this issue is seriously reviewed. Respectfully, Danielle Schasse, Silver Kirin Enterprises