| Comment Number: | 522418-07606 |
| Received: | 7/11/2006 12:03:48 PM |
| Organization: | |
| Commenter: | Ingraham |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear FTC, I am writing this message to provide my input to the Business Opportunity Rule (16 CFR Part 437) and the impracticality of the provisions. Please note that I agree protection for consumers is important, yet the proposed requirements can be impossible to meet. For instance, most companies I have investigated have a product return policy. If a person does not want the product, return it. As for the cost of starting a business, that is not refundable and should not be considering that starting a sub shop takes money and that money is not refundable should the business owner not continue operations. The cost to start a direct selling company is miniscule compared to the cost of a traditional business. As for the list of references, people may not want their information given out to strangers so they can be contacted. Considering the concern about identity theft, I know I would not want my data supplied to someone I have not talked to, even though I may live in the same city. With respect to earning claims, I agree that people should have accurate data supplied to them. I would not want to supply my earnings in paper form, nor should the company make private information available to the public. Traditional businesses that are not publicly traded do not have to supply such data to potential customers. As for legal actions, I believe that the provisions should include the outcomes of the legal proceedings. However, that company should direct the prospective customer to the information available in public records. With respect to cancellations and refunds, I believe that this information is personal and should not be subject to review by anyone. Why should a person be able to make judgments based upon only the data shown, without the underlying reasons for cancellation? Maybe a person died and their heirs cancelled the order. This has no bearing on whether a customer should buy from a company or not. This proposed legislation, while a basis for an important concern, is too restrictive on the industry. A start-up company cannot meet those requirements, and a 7 day waiting period may make it impossible to even start a direct-selling company. Think of the tax revenues that would be gone, and the lack of opportunity for Americans to achieve the American dream. Please find a way to help people who want, or need, information, but do not restrict the growth of existing companies nor impede the creation of new enterprises. Thank you, Mr. Ingraham