| Comment Number: | 522418-07798 |
| Received: | 7/11/2006 6:50:48 PM |
| Organization: | |
| Commenter: | Rita Kinzalow |
| State: | TN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am a veteran teacher of twenty-five years. As I began to look closely at retirement, I realized I would not be able to live the life I am presently accustomed to using the established retirement system. I began to look for alternative ways to secure my financial future. Xango has given me the opportunity to build a profitable business organization that will help me meet my future financial goals. I have gained new confidence in myself as a leader, in my ability to help and serve others as well as setting and working to achieve my goals for the future. I appreciate the FTC for it's consumer protection priorities, but I strongly feel Business Opportunity Rule R511993 would unfairly target legitimate direct sells businesses while posing only minor inconveniences to fraudulent groups. I disagree with all five disclosure requirements of Rule R511993, but am most concerned with the "Seven Day Waiting Period" and the "List of Nearest Reference". The "Seven Day Waiting Period" suggests a level of risk that is non-existent in Xango. Xango has a very minimal up-front investment as well as a generous buyback policy for prospective purchasers. The air of suspicion that prospective purchasers would feel when told the FTC requires a "Seven day waiting period" greatly concerns me. My current practice of sharing this opportunity with people not in my same geographic regions would be hampered by this waiting period for those seven days would more likely become fourteen days as I wait for the necessary disclosure papers to be delivered through our mail system. How many cars, appliances, or electronics would be sold if consumers had to wait seven days or more before the purchase could be completed? The paramount concern with the "List of Nearest Reference" is the confidentiality and privacy of all those involved. With identity theft on the rise, this one disclosure alone would discourage participation in the direct selling industry and would not be a deterrent to fraudulent businesses. It would be impractical and an infringement on the rights of US citizens to have their personal information sent to anyone looking at a business who could possible include the competitor of that business opportunity. I am deeply concerned that unscrupulous business opportunity groups will continue in their deceptive business practices while ligitimate businesses may be driven out of business if Business Opportunity Rule R511993 is passed.