| Comment Number: | 522418-07305 |
| Received: | 7/10/2006 12:45:16 PM |
| Organization: | Xango |
| Commenter: | Edward Murphy |
| State: | VA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
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 presented form, it could prevent me from continuing as an Independent Dirstributor with Xango and destroy my small business. I have been an independent distibutor with Xango for 3 years, this coming August 15, 2006. I started my Network Marketing business because I was seeking an additional income opportunity. I have spent 40 years in the hospitality industry and it is time to slow down. I like the MLM model because it gives me the freedom to work at my own pace with a simple business plan that any serious business builder could follow. I have built a reasonable sized business in the past 3 years, that is a great supplement to my current income. I am building my Xango business with the thought that the part time income will becomemy full time income. I believe as I understand FTC Rule R511993, the proposed requirements would certainly hinder the simplicity of the MLM model and also eliminate some of my current income as some of my part time partners would find this rule too much of a bother and decide to terminate their relationship with Xango. Some of the sections in the proposed rule would make it hard or almost impossible for me to sell Xango's product and services. The 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 Xango already has a 90% buyback policy for the product. One of the dynamics of the MLM business model is the ability to create excitement for a prospect. The opportunity to earn extra income or full time income with their own business. The 7day waiting period would act as a deterent in someone peaking too soon and then having to wait 7 business days to begin actually working their new business. It is not like they have to buy land, site development, FF& E budget, OSHA rules, zoning, bank financing etc. as with the typical franchise opportunity. I have the ability to offer someone a way to beging working now on their own business. Xango's distributor kit only costs $35.00. 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 burden could destroy my business. 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, 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, Edward D. Murphy