| Comment Number: | 522418-06548 |
| Received: | 7/6/2006 5:29:33 PM |
| Organization: | |
| Commenter: | Annette Spriggs |
| State: | MD |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-06548.pdf Download Adobe Reader |
Comments:
Federal Trade Commission Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 Re: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule, R511993. I believe that in its present form, it could prevent me from continuing as a XanGo LLC Independent Distributor, and could very possibly destroy my small home-based business. I have been an Independent Distributor with XanGo LLC for approximately seven months and it is the best company I have ever been associated with. For the first time, I feel that my goals in life can be reached with XanGo LLC, as it is currently set up. Originally, I started my network marketing business with XanGo LLC because of the great business opportunity. My family and I tried the product and are very pleased with it. Now I am able to earn some additional money. With additional effort, I see where this opportunity can grow to meet all of my family’s needs. Even now, my family depends on this additional income to supplement our budget. Please do not destroy my small home-based business. My family needs it! Some of the sections in the proposed rule would make it very hard or almost impossible for me to sell the business opportunity of XanGo LLC and its product. First, the proposed waiting period will give the public the idea that there is something wrong with me and/or our plan. It would make enrolling a new distributor very difficult. I also think the seven-day waiting period is unnecessary because XanGo LLC already has a 90% buy-back policy for all products including the sales kit purchased by the independent distributor. Under the proposed waiting period requirement, I would need to keep very detailed records when I first speak to a prospect and will then have to send in reports to my company. This additional administrative undertaking would prove to be very burdensome, not to mention impractical for me. Second, the proposed rule requires the disclosure of a minimum of ten prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Being a female, I believe this proposed requirement could make me and others a target or potential subject to sexual and/or racial harassment. For me personally, this increased potential risk is unacceptable yet avoidable if the FTC would withdraw this requirement entirely. In the alternative, the FTC needs to modify this requirement prohibiting sexual or racial attacks related to this disclosure. In the end, the rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. Over the years, I have seen many scams on the telephone, internet, in the mail, as well as being approached by many unscrupulous people. This proposed rule will do nothing to stop those who are the true culprits and criminals! I appreciate the FTC’s mission to provide greater protection of consumer rights; however, the proposed rule in its present form does nothing to stop the true criminals but will end up hurting alot of legitimate direct selling business owners. I understand there are a lot of fraudulent groups out there; however, this particular rule does not stop those fraudulent groups; however, it does unfairly target legitimate direct selling businesses. I’m pleading with you to reconsider the proposed rule in its present form and modify it to more accurately target and punish those fraudulent and unscrupulous groups that are hurting the direct selling industry as a whole and more specifically the legitimate direct selling business owner such as myself. Thank you. Sincerely, Annette M. Spriggs