| Comment Number: | 522418-06629 |
| Received: | 7/6/2006 10:27:11 PM |
| Organization: | Pre-Paid Legal Services, Inc. |
| Commenter: | Kevin Wallace |
| State: | VA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it could prevent me from continuing as an Associate and destroy my small business. I have been an independent Associate for more than 4 years. I joined because I had been looking for a way to have my own business without paying tens of thousands of dollars to start one or to buy a franchise. I had tried different businesses in the past and had been scammed and ripped off by a few of those, but finally I found a legitimate, solid, NYSE company with which to align myself. I absolutely love their service and it is so needed in this country. They provide identity theft protection and legal access for people in North America. The company is doing so much good for families with their services and especially their business opportunity. My family counts on this extra income to supplement our budget. Please don’t destroy my small business. We need it! Some of the sections in the proposed rule would make it hard or almost impossible for me to sell my company's services. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new Associate. This waiting period will give the public the idea that there’s something wrong with me or our plan and also reflects badly on me. I also think this seven-day waiting period is unnecessary, because Pre-Paid Legal already has a refund policy. Our sales kit normally costs only $249, however, right now most people can join for under $100. People buy TVs, cars, and other items that cost much more than that and they don’t have to wait seven-days. Under this waiting period requirement, I will need to keep very detailed records when I first speak to a prospect and will then have to send in reports to my company. I am a small home business and this burden hurt or destroy my business. This proposed rule is bad for all of the small business owners in this industry. Finally, the proposed rule requires the disclosure of a minimum of 10 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. Women in my organization may be subject to sexual or racial harassment so this part can’t go in at all, unless the FTC passes an addition to this rule 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. In conclusion, I have seen many scams on and off the Internet. This rule will do nothing to stop them. They hurt my business! This rule will not stop Crooks – they violate the current rule all the time. But I am a good American citizen and it will hurt me. Thank you and please help me. Sincerely, Kevin Wallace