Comment Number: 522418-05840
Received: 7/3/2006 8:20:06 PM
Organization:
Commenter: Abigail Veloso
State: CA
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 writing in response to the proposed New Business Opportunity Role R511993, if not modified, will be a significant impediment & burden to the network marketing industry. This new rule, I believe, will be a significant burden to the free market trade. I don't agree & am opposed to the 7-day waiting period because it is an excessive burden to any company and distributor who would be required to document & follow-up on the business & would be trying to sell a person twice on the same business opportunity. I agree that a earnings claim statement be made but should just be of an average earning but don't agree that we be forced to provide written substantiation because this also is an excessive burden considering that the investment of money to enter into this type of business is nominal. As for the release of any information regarding prior litigation & civil or criminal legal actions, even if innocent, should not have to be disclosed to a new business associate. Disclosing previous litigations of companies, executives & others should only be done if the parties were found guilty. Lastly, the rule also says that the disclosure of a minimum of 10 customers closest to you is required. May I suggest that contact information be available through the company directly as this may also be a burden to distributors if you have to require them from each distributor. The network marketing industry has come a long way. It was once looked down upon by many investors but now even Warren Buffet owns 3 & Donald Trump would even go into the industry if he had to start over again, when asked on the Tonight Show. This industry is being used by blue-chip corporations such as Citigroup, Coca Cola, MCI and IBM. Top business management leaders, such as Robert Kiyosaki, Paul Zane Pilzer, and others have endorsed network marketing. It has also helped in our U.S. economy and in 2003 has contributed about $29 billion into our economy. I have only been involved with network marketing for almost 2 1/2 years. My husband and I got great benefits from using the products and after studying the industry for several months decided to get involve on a full time basis. This home based business helped me a lot and gave me the freedom to take care of my aging parents and also earn additional income without job limitations. I understand and respect the role of the FTC but I believe that this proposed new rule is more than necessary and needs significant changes. I believe that a better approach would be to provide consumers with objective information when analyzing business opportunities and let them proceed when they do get it. So, I do support that disclosures be made during the sales process without the requirement of a 7-day waiting period, only if modified as suggested. Thank you for reviewing and posting my comments. Sincerely, ABIGAIL VELOSO