|Received:||6/19/2006 3:49:46 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Having been involved in the direct sales/network marketing industry for over 25 years, I have been exposed to some great companies, and some not-so-great ones. However, being associated with companies such as Mary Kay Cosmetics, Herbalife, Amway, NSA, and currently, Xango, has given me the chance to not only increase our household income, but to help others while doing so. My experience began when, as a young bride, we joined Amway. I gained more confidence in myself, and was able to relate to people about products, which I'd never done before. Then, with Herbalife, our health began improving, along with our income increasing. When I joined Mary Kay, I had the opportunity to actually, visually, see the rise in self-confidence in the women who became my clients. It was an awesome experience. When it became apparent that our local water supplies were becoming detrimental to our health, we joined NSA, having found their water filters to be superior to those in the retail market. This endeavor also increased our household income substantially. And, now, we are eager to share the beneficial results we, as a family of five, have received by not only consuming the mangosteen juice ourselves, but have personally witnessed with many, many others! Had we not had the direct sales/network marketing model, I dread to think of where our family would be, not only physically, but financially as well. It's given us the opportunity to share our experiences with our 3 children, all of whom are developing as entrepeneurs themselves. (The 'American Dream' continues!) I understand that your priority is to protect consumers, such as myself, and I appreciate your diligence in that calling. However, I am deeply concerned on the impact the proposed rule would have on legitimate direct selling companies! This rule unfairly targets these businesses, while the fraudulent companies will find a way, a loop-hole, around it, one way or another. The efforts of many independent distributors, like myself, will be hampered, to say the least, if not destroyed by casting direct sales in a negative light. Besides causing unnecessary delays, the record keeping and administrative portions of the rule would cause not only impracticality, but huge administrative problems, thus literally squelching the desire of regular citizens to 'get ahead.' As I noted several companies earlier, I'd like to report that none of them required a great investment! Sales kits were/are reasonably priced, and are invaluable tools in starting independent distributorships. In conclusion, for the above stated reasons as well as the rule making it difficult to collect required data and, as mentioned, the fraudulent will always find a way around the rule, regarding earnings claims, besides finding '10 nearest existing sales people' being highly impractical, I have deep concerns regarding the privacy and safety issues, and possible corporate liability for ID theft regarding the 'References' portion of the rule. It is, therefore, my request that you, the members of the FTC, seriously consider the ramifications of such a measure before going hastily on a downhill slide that could very quickly become more of an avalanche. I am and will be monitoring your responses, as well as those of my elected representatives in Washington, D.C. And, I pray that each of you will search deep within your own heart to determine the best, most-logical, and most contributionally effective approach on this measure. Thank you for your diligent consideration in this most urgent matter.