|Received:||6/26/2006 4:12:32 PM|
|Organization:||Independant Distributor for XanGo, LLC|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:While I appreciate what this proposed rule is designed to do to prevent fraud, I strongly suggest that it would do little to prevent the hucksters & crooks from continuing to rip people off. And, it would really hinder legitimate companies from offering quality business opportunities to people who are looking for a second income. I have been in network marketing for over four years. I have been involved with two companies (Ecoquest, & XanGo). Now I only work in XanGo. The income that is generated from this business is primarily paying for my son's current college expenses and contributes to paying back the Federal Stafford Loan on my daughter's past college expenses. This rule change would severly hinder my ability to continue paying these expenses. I am a pastor full-time, and a network marketer, part-time. Please do not impose this rule. Speciffically: The elimination of the $500 business threshold imposes on business like mine a host of requirements that time consuming and far more suitable to opportunities that require much higher investments. Our Dealer Kit requires an investment of only $35 (plus shipping). To require a 7-day waiting period for such a meager investment seems harsh and accomplishes nothing. It is just impractical. The requirements for Litigation reporting are unfair in that it does not distinguish between winning and losing lawsuits and therefore requires the reporting of litigation that has no relevance to the person considering the opportunity we offer. The provision that is the MOST problematic for me it the requirement for the 10 nearest existing sales people. I prospect all over the nation through purchased leads of people who request the information I have. Not only would it be difficult to determine which 10 people to include as references, but I do not like the idea of being required to pass along private information that could be abused by a potential prospect. This is dangerous to say the least in todays' mixed up world. This creates liabilities for me as a distributor and also for the FTC if this information would be misused by a criminal. Please don't require us to give out personal information about our customers. Those who aren't legitamate businesses would fake the information, resulting in penalizing the good guys and doing nothing to stop what you are trying to stop. Please do not make so many requirements that those who are trying to obey existing laws and requlations are so encumbered that doing business profitably is impossible. What should be happening is that those who break existing laws and are indeed scam artists should be punished. This proposed rule change does very little to hamper the crooks but severely punishes those who are ligitimate part-time business owners. Thank you for allowing me to comment.