| Comment Number: | 522418-08948 |
| Received: | 7/13/2006 5:58:57 PM |
| Organization: | Xango |
| Commenter: | Janell Cirkl |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
This is a comment referring to the Business Opportunity Rule, R511993. I am a relatively new distributor, whose sole purpose is to let others receive the benefits of this exceptional product. In 1971 I was involved in a MLM that made me be very cautious about MLM's. It was Holiday Magic and although it was an wonderful skin care line, the emphasis was on making money and bringing in new distributors, as well as a large financial commitment up front in order to be involved. Some of the proposed regulations are important to prevent a company like this one was. I have waited all this time to get involved again in am MLM. With the new proposed regulations, for all MLM's it would be extremely difficult for the new distributor to be involved (7 day waiting period) and would be discouraging to anyone wanting to start a small business. (The record keeping ; ie disclosure of documents pertaining to nearby distributors, requests for rescinding of agreements, numbers of those not involved any more, specific amounts of money earned etc, that are proposed requirements to be given before agreement to become a distributor. Obtaining these numbers would be so frustrating for me and many people I know.) I am a distributor because of what the product has done for me. I have tried (as a consumer) many other similarly promoted food suppliments (ie; Sea Silver, Frequency, Noni) and although they helped me some, none of them have been as fantastic for me as this product. My husband and I are self employed, owning mail processing business, with very expensive and very few benefits. Xango has made it possible for me to stop taking all my prescriptions (Celebrex, Celexa and Tylenol), which I had no prescription insurance for. I have joined Xango in order to save myself money on retail purchase of the product and have totally eliminated my very expensive drugs. As a benefit of distributorship I have shared this product with others who now have signed up to be distributors themselves. I have educated myself on this product and am thrilled to educate others. I believe the restrictions on this particular company, Xango are far too restrictive for this MLM. The cost of $35.00 is so minimal to start getting a discount and to start promoting a business of such a high quality product. The requirement of 7 day waiting will cause far too long of a delay for those who want to start feeling healthier as soon as possible and start a business. Seven days also will give all consumers a false impression that this product has something to hide and does not help anyway. Both of which are not true and are damaging to this excellent product. This product is also one which is consumable, so to require money back for purchase is unfair to the distributor. Please do not require all the up front documents and disclosures. There is no reason that with electronic communication of today this information cannot be obtained on the internet, provided by the company, not the distributor. I realize that the consumer must be protected from the many fradulent businesses out there, and I believe the FTC is working hard to protect comsumers. However, not all MLM's are bad. To penalize those good ones, and to keep new distributors from starting at a minimal investment with so many restrictions and demands is excessive. Make disclosures available on the internet, a website run by the company, but do not require all distributors to have them in hand. As far as knowing the 10 nearest distributors, this would be next to impossible, a sure fire way to discourage me from participating. We live in America, a land of opportunity to work toward our goals and achieve financial comfort. Do not control everything in our lives, go after those dishonest MLM's, but don't catagorize all MLM's as dishonest. Thank you for your time and consideration. Janell Cirkl 1K distributor of Xango, Minnepaolis MN