|Received:||6/30/2006 1:14:34 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I understand the need that drives this law and I feel that parts of it are right on the mark but I fear it may put me out of business and back onto fear of retirement. I know we need to protect the public and keep Con Artists out of the market. I also know unscrupulous persons are all over out there that are ready to prey on the naive or innocent, but targeting law abiding and effective direct sales companies is not the best answer, in fact it may cause the only ones to remain in the business to be the liars and frauds, who would just falsify records anyway That is what is already happening in the contracting industry in CT… I got into Direct Sales because my second wife has been in it for 16 years although with a different product. I researched the Direct Sales company while I used the product and found it’s claims to be UNDERSTATED but that never would have happened if I had to wait a week before I could sign the contract… during the first week I had my entire family talking me out of it (all 5 sibs and my mother), but I knew I had 30 days to evaluate it free of charge (30 - day, money back guarantee) and they have held to that for 2 of my recruits that decided that they didn’t want to do it.. I have received NO complaints at all about the product or the system…I have only been in Direct Sales for only 6 months. But the 6 mo. has changed my life… My Direct Sales business has already doubled the funds I have saved for retirement, and it has more than paid itself several times over. Direct Sales has had an immense impact on my life in other ways as well, it has given me people skills that I have used all over my life, marriage, and family. I have a confidence now that has replaced an immense inferiority complex... As I before said the waiting period is clumsy and causes me to spend more cash to hold records and do call backs and is almost guaranteed to drive my 10% interest ratio (those interested in even listening to the market plan) down to less than 1%.. The earnings claims requirements will cause my parent company to increase the membership fees I now pay to a level that can easily eat up all my profit, and criminals will just falsify them anyway… The franchise laws were developed for people spending tens of thousands of dollars for a McDonalds or Burger King, not me with my initial $100 investment… I can’t even Understand the wording of half of them and would probably just drop my business because now it would be too complex to understand, and I’m a College grad!… I do 50% of my business over the internet through legitimate ad campaigns and for my parent company to be able keep the 10 nearest existing sales people available means retooling several systems, and will again increase my membership fees past affordability, If the burden is placed on me then it becomes impossible. If the litigation reporting just require them to show the justified lawsuits then it would be great, but it also requires companies to report frivolous and downright false lawsuits. This can easily lead to misinterpretation and still again a con will falsify this to his betterment, or just change business name, ownership, and location to appear clean as a whistle ( I site contractor-cons in the news lately here). Please rethink this law to be fair to both the public AND the companies involved… As a consumer of goods and services, I appreciate the work you do. On my behalf, and for the many consumers that do not know about the work you do, thank you. As a businessman I appreciate your efforts to bring about order in the business opportunity market. I am sad to say, the proposed Business Opportunity Rule, R511993 falls far short of that objective. Many of the rules and regulations proposed would seriously stifle competition among legitimate sales people, distributors and companies. The relatively few frauds in the business opportunity market that give the industry a bad name.