Comment Number: 522418-06528
Received: 7/6/2006 4:10:48 PM
Organization:
Commenter: Belliston
State: UT
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

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 I got into Direct Sales because my job was a dead end with no money and no end in sight. 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 trying to talk me out of it, but I knew I had 30 days to evaluate it free of charge (30 - day, money back guarantee). I have received NO complaints at all about the product or the system…I have only been in Direct Sales for only 3 months. But the 3 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...I didn't before! As I said, the waiting period is clumsy and would cause 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 the criminals will just falsify them anyway. The franchise laws were developed for people spending tens of thousands of dollars for large national franchises, 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 re-tooling several systems, and will again increase my membership fees past affordability. If the burden is placed on me then it becomes impossible. Lastly, if the litigation reporting just required showing 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. Cons are everywhere and we who work for legitimate companies will be hurt terribly! This law will not end the problem it will just make it harder for us (as hard working Direct Marketers) to make a living. We may just as well go back to our $9.00 jobs and try to support our families that way! Please rethink this law to be fair to both the public AND the companies involved. Sincerely, Ms. Belliston