|Received:||6/21/2006 3:59:13 AM|
|Organization:||Formerly of Equinox International, Quickstar, Family of Eagles & Synergy|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Having had a great deal of experience in the Direct Selling/MLM industry, I am wholeheartedly in favor of this proposed rule as written. These business "opportunities" are too often couched in sound business theory designed to obfuscate the very real challenges and obstacles that prevent the vast majority of those who get involved from making the monies that are dangled in front of prospects like a carrot. I currently work in the real estate industry in Colorado and by law we are required to disclose any material fact that may effect the properties and transactions we are dealing with. The Direct Selling/MLM industry has no disclosure requirement and as the result many people are often duped into believing that if you work hard, offer the "opportunity" to everyone you know and sever your ties with anyone who doubts or is skeptical ("energy thieves"), regardless of how long they may have been a valuable member of your social circle, you will make enough money fast enough to become "Independently Wealthy" enough to do as you please with your life in a short amount of time. Despite my success as an independent small businessman & Realtor, I never once did more than break even in any of the numerous Direct Selling/MLM groups I have worked with in the past. This is obviously NOT due to a lack of effort, marketing or selling talent on my part. Also, in almost every case the products were superior and would almost sell themselves. The problem with these groups is their structure and that they almost universally deny the prospective "distributor" ALL then information with which to make an INFORMED decision on their part. Like a cult, these organizations operate for the benefit of the few at the top of the pyramid while dangling the carrots of financial freedom and independence in front of people who often desperately grab for them. If an industry is truly honest, straight forward, ethical and vibrant, then it shouldn't fear disclosure or a waiting period. Only the ones with something to hide fear either, and they are precisely why this rule is needed.