| Comment Number: | 522418-03468 |
| Received: | 6/20/2006 7:46:53 AM |
| Organization: | Xango LLC |
| Commenter: | Gilchrist |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
First of all, I want to thank you for taking the time to consider a ruling to try to limit the number of abuses in the direct selling industry. I have been in the industry for over 15 years, and provide a way of life for my family. The products have supported my family's health in ways that are even more valuable. It is with this concern that I write this letter requesting that the violators of improper trade practices be fined more money, as opposed to enacting the proposed rules.This rule unfairly targets legitimate direct selling businesses. The seven day waiting period casts the direct selling industry in a negative point of view, creates additional costs with administration and record keeping, and unnecessary delays. The elimination of the $500 threshhold forces the majority of direct selling companies to comply with other provisions of the proposed rule that are more appropriate for businesses requiring a greater investment than a direct selling sales kit. For the earnings claims proposal, it will be difficult to collect required data. Targeted abusers will provide bad data, while legitimate companies will try to provide accurate data. There are privacy and safety issues with the references, along with possible liability with identity theft, and the impracticality of finding the 10 nearest people. (especially in our global environment) Again, we appreciate all that you do to keep trade fair and equitable for everyone. The direct selling industry has standards and those that abuse them can be penalized and even barred if necessary. It is unfair to limit the ability of legitimate business owners with these rules for the majority who run their businesses ethically. Thank you.