| Comment Number: | 522418-04169 |
| Received: | 6/25/2006 3:35:40 AM |
| Organization: | |
| Commenter: | Raymond Virzi |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have always been concerned about protecting people from multi-level marketing scams. However, some of these companies are legitimate means for average people to earn extra income, one of which I am a member (called Financial Destination, Inc.). I benefit from the membership without having to sell to others. I support some legislation that would allow better disclosure to prospective clients, but if these rules are over burdensome, it could jeopardize the very existence of a small company and penalize those who benefit from it like myself but choose not to sell it to others. I think that the FTC could draft such legislation while at the same time being senstivie as to the financial and administrative burden it might impose on these companies. Other items in the current bill seem unfair. Disclosing past lawsuits might be misleading due to frivolous suit cases, unless the disclosure only requires those cases that had been actually been judged against the company. Requiring references would not make sense since the companies are based on credits for sign-ups, and if the salesperson had to disclose other potential salespeople, it would interfere with the client acquisition. After signing up, there is usually no need for references because the new member is introduced to many others in the company, but such a requirement after sign up would be acceptable and allow the new member to cancel if not satisfied. Requiring a full refund period is standard business practice and many of these companies already do this. All I ask is that the FTC would draft this bill to give a fair representation of both the companies and their prospective members. Thank you for your time.