| Comment Number: | 522418-08850 |
| Received: | 7/13/2006 3:34:16 PM |
| Organization: | XanGo |
| Commenter: | Judith Hicks |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: Business Opportunity Rule, R5112993 The inpact of the 7 day waiting period will be devastating to a potential purchaser, and individuals wanting to participate in XanGo business opportunties.Not only will this create undue suspicion, but a hardship to established distributors. The 7 day waiting period suggests risks that do not exist with XanGo. XanGo's buy back policy presents little or no risk and has one of the lowest up-front financial investments in MLM. Listing references as part of the disclosure requirements imparts information that is confident, and evokes privacy concerns. This available information will have to be given not only to purchasers but to anyone who shows interest by contacting a distributor. This opens the "reference information" for any use or purpose. It would not keep any company from using fraudulent list of "references". The earnings claim statement is again a disclosure that can be minipulated even with statistical time periods. XanGo supports a substantiated earnings claim made by business opportunity sellers, but again this will not deter fraud, because fraudulent companies will provide data that is not accurate. There are many unethical and unscrupulous people that are out to swindle people in their effort to make a profit through MLM. Not all MLM are created equal, but XanGo has set its sites through its distributors to manage their business with the highest degree of truth and candor. No sale is worth sacrificing our intregrity. Many of the issues proposed leave few options for the MLM and will only inhance fraudulent business opportunities. I think it is paramount that the FTC find new options to protect the public, and not inhibit the sucess of the MLM.