| Comment Number: | 522418-09138 |
| Received: | 7/13/2006 11:44:13 PM |
| Organization: | |
| Commenter: | Clark |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: Business Opportunity Rule, R511993. As I begin to tell my story I want to express my appreciation to the FTC for wanting to protect consumers from fraudulent and deceitful practices. With that said I would like to tell you how some of the newly proposed rules would effect my new business. I have been involved with direct marketing for about six months. The potential to add extra income to my home has been appealing since we are a one income household. I have been steadily trying to build my business and have seen some progress over the last few months. The new rules that pertain to a seven day waiting period and providing lists of 10 users in my area are going to be very burdensome for a couple of reasons. My schedule of work and travel mean that I have to be very deliberate about spending time on my business. Many of my prospective customers are met in the course of my travels so as with many sales opportunities it is important to capitilize on an opportunity when it takes place. With a seven day waiting period the opportunity has passed and the likelihood of it repeating or coming to fruition is greatly reduced. When someone decides to become a distributor my company has very generous policies that will refund them if they decide that they don't want to continue. That policy is more than four times longer than any suggested 7 day waiting period. This leads into my concern about providing a potential customer with 10 customers from the local area. This becomes a bureaucratic challenge that I would have great difficulty meeting. My organization would have their private information given to a complete stranger. This could lend itself to unwanted contact by a stranger and people could use these lists to try to give them an advantage in building their own business. What I am saying is any list would carry the burden of "proving" that these people exist and the only way you could do that is to give personal information and invade privacy. I have only addressed two of the areas of the Business Opportunity Rule, R511993. Time does not permit that I address other areas. In summation, I just want to say that the appeal of earning extra income through direct marketing would be greatly hindered if hurdles, (even though they are intended to protect), cause more work for someone like me that is already doing this on restricted time availability. I hope that you will reconsider implementing Business Opportunity Rule, R511993 in its present form. Again, I appreciate the desire to protect from fraud and deceit. I hope that it can be done in a fashion that won't be so burdensome. Sincerely, Kelly Clark