| Comment Number: | 522418-05962 |
| Received: | 7/4/2006 4:42:13 PM |
| Organization: | P K Enterprises |
| Commenter: | Frederick Kemmerley |
| State: | SC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife and I very concerned about your proposed rule concerning business opportunities like our business. The income which is derived from a business like ours is not well defined like income from a job. Our income is based on our performance. As a result, it is virtually impossible to predict what kind of income a new person might develop. We have always indicated what levels of income are possible according to the various levels of achievement. We never guarantee any level of income. We would recommend some standardized income disclosures that would apply to all direct sellers. We do not see any need for a cancellation policy because our affiliate will refund the registration fee of anyone who changes their mind. We would also not see any need for a waiting period for the same reason as just stated above. With regard to providing prospects with references or past litigation or financial records of present Independent Business Orders, we would see these requirements as not necessary because they would not help prospects to understand the nature of the business and what they need to do to be successful. The revelation of private income information again would not be helpful because what a prospect might be willing to do will be based on their interest and not on the past efforts of an existing Independent Business Owner. All through the 14 years which we have done this kind of business, we can hardly recall any prospect asking for references or for past litigation against the corporation. Again, prospects usually ask how the income is developed and what they need to do to earn the income. Our personal income developed from our business is private and confidential information. In addition, what we have done and what a prospect might accomplish will likely be very different outcomes. In conclusion the proposed rule would have a serious negative impact on our ability to do our business while at the same time not being of any productive benefit to prospects for our business. We would urge the FTC to give serious consideration to the recommendations of the Direct Selling Association.