| Comment Number: | 522418-06722 |
| Received: | 7/7/2006 9:28:11 AM |
| Organization: | D & J Clean Air, Inc |
| Commenter: | Dennis Gillen |
| State: | NC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-06722.pdf Download Adobe Reader |
Comments:
July 7, 2006 Dennis and Jane Gillen D & J Clean Air, Inc Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) Re: Business Opportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: We are writing this letter because of our concern about the proposed Business Opportunity Rule R511993. We believe that in its presented form, it could prevent us from continuing as a Distributor with EcoQuest International and destroy our small business. We have been independent contractors/distributors with EcoQuest International for over 11 years – since November 1994. Originally, we started our Network Marketing Business because the products changed our life for the better. We loved them, wanted to share them with others to help them and to earn income for our family. Our family depends on this income. It is our full time occupation. Please don’t destroy our small business, we need it! Some of the sections in the proposed rule would make it hard or almost impossible for us to sell our EcoQuest products. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new Distributor. We are like any other company attempting to staff our business. Major corporations have to hire significant numbers of employees each year to enable them to continue selling their products or services. There is a large number of turn-over of employees in the fast food industry. Seasonal hiring is a critical need to the success of many businesses. Companies occasionally need additional employees for special events. Just as it would be to these businesses to have a waiting period to put these people to work after hiring them, it would be most disruptive to us as well. EcoQuest International’s business owner kit only costs $ 49.00. 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 would be a burden that would hurt or destroy my business. This proposed rule is simply big government intruding into an area where it is not necessary and it is a bad idea. 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. I have seen many scams on the Internet and been approached by many crooks because of my success. 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, Dennis & Jane Gillen