|Received:||6/21/2006 5:37:33 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:FTC, While I agree with some of your proposals There are a few that would cause undue impact on our business. I would wish you to reconsider 5 of the provisions . 1. Seven Day waiting Period. This proposal would dampen new members from joing our company,As we already implement a free sign up and a 90 day period to join. 7 day waiting suggests a risk that doesnt exist in our company. 2. Lists of Nearest References. This requirement is overly burdensome and evokes confidentiality and privacy concerns for all involved. 3. Earnings Claim Statements. This requirement will not deter fraud, A fraudulent company will not provide accurate data, While legtitimate business oportunity sellers will have difficulty in meeting the proposed requirements. my company believes that earnings from business oportunity should be substantiated. 4. Legal Actions. this requirement wants to disclose all actions regardless of the outcome, This rule would not require disclosuer of the outcome of the litigation if in favor of the Company. 5.Cancellations and refunds. Requirement would place undue burden on thousands of small business's and punish those companies with such a liberal rule. we have always emphasized to all independent members that all requests for cancellations and refunds be liberly granted..