|Received:||7/1/2006 8:06:17 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:The proposed FTC rule regulating the way small businesses conduct their recruitment is excessively restrictive. The FTC should create a level palying fiely by requiring cear,simple,and standardized disclosures that apply to all direct sellers. In addition a appropriate, reasonable cancellation policy should be implimented however, a seven-day waiting period before a prospect could register is very opressive. These are not "franchised business opportunities" and the Rule should not mirror franchising. These are small investment, usually under $200 and should not be treated as at significant franchise type investment. Providing references from other independent business owners is unreasonable. The independent business owners in our business are entitled to be priviliged and not open to others wishing to participate under a similar business format. The issue of litigation is very difficult. In this litigeous society there are so many frivilous suits. Revelant litigation would be appropriate but who and how is that determined? Most troubling is the proposed requirement that financial records be disclosed. This is private business. Not public companies that have similar requirements. unconscienceable that private financial information from a independent business owner that might be participating in the direct sales business would be required to be disclosed. This all appears to be a case of severe over reaching by a federal agency. I would trust that our interests in the protection of promoting small business - very small businesses - would not be curtailed by this proposed rule. The IRS has already made every effort to discourage our direst sales business and the opportunity that small independent business owners seeks. Please don't take a similar position and further minimize the opportunity for the American Dream to be realized by our independent business owners.