| Comment Number: | 522418-08682 |
| Received: | 7/13/2006 10:14:24 AM |
| Organization: | |
| Commenter: | Ralph Stephens |
| State: | IA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
While I appreciaate the effort to protect the public from unethical business opportunities and fraud, after reading this proposed regulation, I do not see that it will accomplish the stated goal. I do see how it will impose huge burdens on legitimate businesses and may force some forms of business to cease to exist, particularly the network marketing businesses. The 7 day rule is burdensome to both business and customers. Why should I have to wait 7 days to invest in a business. This isn't life threatening like an abortion and waiting periods are found unconstitutional for abortion! The disclosure of sales and income is an invasion of privacy and is meaningless. Some people are better sales people thaqn others. Because one person makes $1,000 of sales in a month does not have any relevance to what another person might make. However, it is an extreme violation of privacy having to disclose ones income and sales amounts, making one a target for lawsuits. This will not help potential customers a bit and will subject business people to huge risks. Fraudulent businesses will just make false claims. Legitamate businesses will suffer. Requiring the disclosure of the "10 nearest existing sales people" risks violation of privacy of those peoople, who could then sue the person who gave their names. In the case of health - related products, this could violate HIPPA. This also increases te possibility of identity theft of the disclosed people. This is dangerous to the public (business people are "the public" too. For these and many other reasons, I feel your proposed rules, while well intended, will not accomplish their stated goals and will instead negatively impact a huge number of honest businesses. You are punishing the honest operators and not curtailing the activities of the fraudulent ones. This will not protect the public, it will only restrict their free choice of opportunities. Drop these rules and do not implement them. Thank you for your time and consideration. Respectfully submitted, Ralph R. Stephens