Comment Number: 522418-05022
Received: 6/29/2006 10:29:08 AM
Organization: Arbonne International
Commenter: Lynette Fioroni
State: MI
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 a Regional Vice President with Arbonne International, a direct sales company. I have been active with Arbonne for four years, and have created a second stream on income for my family of five, while staying home caring for my children - the American dream. I have worked long and hard to achieve this success, and the business opportunity has enabled me to overcome many personal problems including a life threatening illness which was nearly fatal. Because I could stay at home with my family and earn poentially six figues,when it came time to return to the work force, l chose the Direct Selling industry. The proposed regulation is extremely bothersome, particularly for those of us in Michigan (where downsizing and unemployment related to the auto industry have forced so many to evaluate other options) for many reasons: The seven day waiting period makes us look bad! it creates a new plethora of record keeping and administrative problems for us and causes many unnecessary delays. The litigation reporting is unfair! it does not distinguish between winning and losing lawsuits. Requiring references is not a bad idea, but it is not practical to find 10 nearby consultants, and there are identity issues ID theft and safety as well. I truly appreciate the goals behind this legislation, and the desire to police potentially fraudulent groups, but this ruling would unfairly target many legitimate businesses, and penalize many of us who have worked long and hard to establish our business, our families, and our lives in the American tradition. Respectfully submitted, Lynette Fioroni Regional Vice President, Arbonne International