| Comment Number: | 522418-03464 |
| Received: | 6/20/2006 3:05:29 AM |
| Organization: | XanGo Distributor |
| Commenter: | Mardis & Lora Coers |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
With regards to the proposed List of Nearest References requirement under the Business Opportunity Rule, it should be noted that a number of network marketing companies are international in scope and, additionally, have the capability to conduct most of their business transactons over the internet. If a person in Mexico, Japan, Ireland, etc. would like to become a Distributor of a US-based network marketing company, would they be subject to the Business Opportunity Rule? What if the person in Mexico, Japan, Ireland, etc. wanted to sponsor a person in the US, would they be required to provide a List of Nearest References to the US prospect? How would the request of the non-US resident for names, addresses, and phone numbers of US citizens engaged in a legitimate US businesses be handled? What happens to that information once it is outside the US? I think the requirement for the List of Nearest References is ill-conceived and is fraught with many scenarios potentially abusive to the privacy of US citizens with the realistic potential to reach far beyond the borders of the United States.