| Comment Number: | 522418-03818 |
| Received: | 6/22/2006 11:38:42 AM |
| Organization: | Xango |
| Commenter: | Fred Gregory |
| State: | AL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern: I am writing this letter because I am very concerned about the proposed BUSINESS OPPORTUNITY RULE R511993. I have never written or call any of my Federal Government offices before about any matter that I had concerns about; though there have been several over the years. I suppose like every other Joe Citizen, I just complained but never voiced my opinion to any governing body. Then why am I motivated to write now? Here is a bit of my story and some of my deep concerns—no—fears about R511993. I am a 61-year-old male. I served four years in the U.S. Air Force and then began my work career. I worked hard in my career, educating my self and getting certifications needed for advancement. By the late ‘70’s and early ‘80’s, I began to realize that hard work alone was not going to provide the security and lifestyle that I desired for my young family. I started looking around for business opportunities. At that time I did not know what a MLM company was or how the concept worked. A good friend introduced me to my first MLM in 1981. Over the years since, I have tried several MLM’s. I gained a lot of confidence and personal growth from the training involved with some of them. I never ever made very much money from any of them, so I decided that though it was a great concept that I couldn’t make it work. There was never any thing wrong with the various companies, just my ability to make it work. Within the last few months, I have enrolled in another MLM, after several years of ”no longer being interested.” The product has worked tremendously well for me personally. For the first time in my numerous attempts, I am beginning to develop a nice MLM business, because the product works. Sir/Madam this is my last ditch effort to develop some retirement for my family and me. PLEASE DO NOT DESTROY THAT CHANCE BY ENACTING R511993. I know your intentions are to GET the bad guys. My fear is that if R511993 is enacted that my little will be stopped in its tracts and my hopes dashed. These days with identity theft on a rampage, most folks are reluctant to divulge, even the minimum personal information needed to enroll them in a program. If they know that their information will be kept in, yet more data bases, very few people would want this. I know I would not. The company that I am involved with now is Xango™ Company with offices in Utah. The enrollment cost and sales kit is only $35, far below the $500 maximum allowed and there is a 90% byback policy already in effect for the kit and initial product purchases. Our company does not require a salesperson to keep any product inventory so when any one wants to enroll, we must order the product for them and allow time for shipment. If a seven-day waiting period were added to this time, it would discourage a lot of people from ordering and make them if there were some sort of problem. Since there is a 100% money back guarantee on product within the first 30 days, Xango™ has gone the extra mile to protect the customer as well as the salesperson, thus making any waiting period totally unnecessary. The aspect of the purposed rule to require disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser is burdensome and invasive. The company would have to keep this database and have it “open” to every sales person to use. This is a very bad idea. I use references all the time of other purchasers for both customers and possible recruits, but only those that I KNOW PERSONALLY AND HAVE PERMISSION TO USE AS A REFERRAL. Many times I am contacting a friend in another state and may mention mutual friends or acquaintances that may reside in their area or in yet in another state than either of us. MLM’s are by their very nature referral-based businesses, therefore, we use this concept all the time, but you must not force us to expose people in our business to possible harassment or worse. I know your intentions are honorable and an attempt to protect the public from predators in the industry. A better way to that is to use existing laws to prosecute the bad guys to the full extent of the law. Please do not kill our industry with R511993, but allow us to continue to PERSUE OUR VERSION OF THE AMERICAN DREAM. Feel free to use my name. Fred Gregory