Comment Number: 522418-06734
Received: 7/7/2006 10:52:08 AM
Organization: Reliv International
Commenter: Phillip Harp
State: AR
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

RE: Business Opportunity Rule R511993 Dear Sir/Madam I am writing with hopes you will reconsider the proposed rule referenced above. I am a fairly new network marketer. I opted for this opportunity to help my family's financial situation. Specifically, I am opposed to the 7 day waiting period and contact information(references), and to a lesser extent, the disclosure of prior litigation or lawsuits. The 7 day waiting period is an excessive burden and would be detrimental to my business. This rule, while possibly written with good intent, is unnecessary, in my opinion. It singles out independent distributors. Can you imagine conducting all commerce under this regulation? Requiring references will be an additional burden for my business. I will most likely lose customers if they must be willing to disclose their personal and purchase information. I believe the litigation recommendation is useful and necessary only if one has actually been proven guilty of some sort of gross misconduct. In closing, I would like to say that I operate my business with the utmost integrity. While I understand there are many 'less desirables' out trying to scam the public, there are also many thousands of independent distributors trying to make an honest living. Please re-evaluate this proposed rule. Quite frankly, if my friend who introduced me to this business had been forced to follow all the rules mentioned in this proposal, I would have had serious doubts about wanting to take a chance to better my family's future. You know, having a waiting period to purchase a distributor kit just doesn't make a whole lot of sense to me when I can go down to the car lot and give them a check and drive off with a brand new car. Which is what I actually did on May 25th. With all due respect, I believe this proposed rule unfairly targets network marketing, which by the way, is an industry that moves billions of dollars of goods and services through our economy. The company I represent has an 18 year track record and is publicly traded on the Nasdaq. They are a member in good standing with the Direct Selling Association. They give a 100% money back guarantee on all products bought by a consumer and a 90% buy back on all products bought by any unsatisfied distributor. That's a better deal than I'll get down at the local hardware store or better yet, the local car lot where I just purchased a car. If I'm not happy with the car after I leave, too bad for me. Once again, please reconsider this proposal. It is going to be very detrimental to my business.