| Comment Number: | 522418-08791 |
| Received: | 7/13/2006 1:38:57 PM |
| Organization: | Quixtar |
| Commenter: | Eli Dragomer |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern: I am deeply concerned about the proposed new rulings regarding Direct Selling and Direct Salespeople. In a world full of rules and regulations, laid out for the good of the majority and to protect us all from predators and thieves, we need to carefully consider the full impact of all our actions, especially when they have such widespread impact as do our rules and regulations. Without further ado, my concerns are as follows: 1. Provide a list of IBO’s in the area. How then, would it be possible to break ground in a new area, or to enter into direct competition within an area where your direct sales have not previously been located? This would give established businesses an unfair advantage in that their numbers would be more attractive to new prospects. The general feeling is more comfortable with mass numbers vice the “new comer” to the area. Also, this requirement would be a violation of my privacy as an individual. My name would be used by others regardless of their business ethic. Bad for me, great for them. 2. Provide full disclosure statements regarding business income. My business team already requires me to provide a financial disclosure statement to prospects. We are very careful to ensure that all prospects and IBO’s remain cognizant of the need to let ourselves and everyone else know what the full spectrum of income potential is, and what is required for the business to succeed. Were I to be discovered doing anything other than this, my business ethic would be questioned, and I would be dismissed from the business. 3. Provide a litigation list. What possible benefit could this provide to my business or to prospects? Is any other business on the planet required to provide such a list? Do automobile sellers have to provide such a list? Banks? Home builders? Congressmen and women and senators before elections? This requirement is disturbing in many ways. These are just a few of my comments regarding the proposed rules on Direct Selling and Sellers. Please do not make life so overly complicated that we will no longer be able to function as IBO’s within a web of nuance and rhetoric. These rulings can only result in additional unanticipated consequences and ultimately will result in fewer and fewer independent businesses and more unemployment. Thank you for your consideration in this matter. Respectfully, Eli M. Dragomer