Comment Number: 522418-03326
Received: 6/19/2006 10:41:05 AM
Organization: Integrative Massage Therapy
Commenter: Marie Gallagher
State: CO
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Good morning. While I appreciate the FTC's protection priorities, I am deeply concerned about the impact of the proposed Business Opportunity Rule R511993 on legitimate direct selling businesses. I am new to this industry; however, I feel that I am involved with a group with the highest integrity and ethics and that at no time have I experienced anything less than complete professionalism with the Xango, LLC group. The business has enabled me to grow as a person as well as be able to plan for my financial future. As a professional, certified massage therapist, the product provided by Xango has helped my clients tremendously. The 7-day waiting period you mention in the proposed rule would create a big hardship with the sales of the mangosteen juice - I have clients that need this product now and making those in need wait 7 days is unreasonable. That proposed waiting period also infers an air of suspicion among prospective buyers when they are told that the FTC requires this waiting time. Xango, LLC already has a very generous buy-back policy which presents very little risk to the prospective purchaser/buyer. The investment to start with the company is minimal, again presenting very little risk. Also, the disclosure requirements (10 closest geographical purchasers) would create additional worry for buyers - they are already fearful of identity theft and it places the Direct Selling Industry in an unfair position. Those involved in fraudulent practices will continue to be frauds, while those in legitimate direct selling business would be affected quite negatively as the appeal of direct marketing would lose quite the momentum. Please reconsider this proposed ruling. Thank you for your time and consideration. Marie Gallagher, CMT