| Comment Number: | 522418-08949 |
| Received: | 7/13/2006 5:59:39 PM |
| Organization: | Tahitian Noni International (Independent Product Consultant) |
| Commenter: | Colleen Loughmiller |
| State: | ID |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern: My comments are about the proposed Business Opportunity Rule. I am commenting because I have been an independent distributor/product consultant for several networking companies about 15 years whenever I found products that were benefical to consume for good health. The past ten years I have been an IPC (independent product consultant or distributor) for Tahitian Noni International. I was unexpectantly widowed in 2000 and experienced the additional loss of income when the stock market crashed. But I was able to pay my mortgage and living expenses with my income from Tahitian Noni International. What if the proposed rules were in place to prohibit my sponsor from telling me about this business opportunity in 1996? I would not have had the financial protection I needed in 2000 when other sources of income disappeared! While the intent is the new rules is clear - to protect the unwary from fradulent business claims - it also removes the opportunity of legitimate business opportunities being presented to those who need them (such as myself). It appears the proposed details of this new rule go beyond the mark and will actually cause harm. I don't want to disclose the exact details of my personal income from any source and do not want to be compelled by law to do so in this industry. It is dangerous to hand out a list of persons whom I have previously contacted to a new prospect. What a huge violation of privacy such a list entails - not to mention the possibility of fraud by a stranger using such a list. How could one supply 10 years of data of advertising and personal contacts? I make every effort to give full and current information, often taking my new prospect to meet the company executives, tour the plant and corporate headquarters, and introduce him/her to my partners (upline sponsors). There is nothing to hide and everything to share. I've even met some of my international prospects at home office and taken them on personal tours. Most recently my husband (as I've remarried) and I met one of his agricultural business associates from Romania at the US corporate offices. He wanted to know first hand about the business opportunity for him as an IPC in Europe. This man is Lebanese, has a US MBA, and is a naturalized US citizen. He read the materials I sent him and came to the US to further check out if this business opportunity was for him. He decided that it would be difficult to open the Romanian market and passed on the opportunity. Any person in my present organization can resign at any time. There is no compulsion to be active in building a business. Many of my associates register to be eligible for a price discount. (Who wants to pay retail when there is a better choice?) A few such as myself chose to build business teams and to teach and coach associates so they can earn a partial or replacement income. I have letters in my file from some of my partner friends expressing gratitude for sharing this business opportunity with them. It has been anything but a sinister experience for them and for me. A few bad apples (companies that blitz business opportunity while not presenting a genuine business building opportunity) can be identified and censored. To saddle all networking or direct sales companies with this excessive disclosure rules is overkill from an regulatory point-of-view. My friend from Romania would be very angry if he were put on a list I am required to give to everyone I present this opportunity to if the new rule is put in force!!! I hope this personal example clarifies my concerns about privacy. Thank you for the efforts of this rule to protect US citizens. I suggest you go back to the drawing board and draft rules that will not injure companies and their representatives with privacy and logistical problems. I appreciate the freedom to work from home and to earn an income helping others. Sincerely yours, Colleen Loughmiller,