|Received:||7/14/2006 2:31:59 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:For over 12 years I have had a successful career in the direct selling industry, most recently with XanGo. When I began, I was a single parent and had an urgent need to earn several hundred dollars a month more than I was able to make in "day" job. My mortgage had been increased by that amount and I wanted to hold onto my home. I was able to hold onto my home and accomplish much, much more...through my direct selling business. Perhaps more importantly, my business provided me the opportunity to develop tremendously as a person - I have acquired excellent presentation skills as well as a solid confidence in my abilities to build a business and coach others in doing the same. My direct sales company also provided exceptional travel opportunities to places that I would not have otherwise visited, based on my the income at my previous job. The travel and other perks have been a source of great delight for me and my family. I appreciate the FTC's mission in protecting consumers and know that there ARE fradulent groups out there. However, the vast majority of companies, especially those that are members of the Direct Selling Association, comply with a high standard of ethics. Direct selling businesses offer the "common man (or woman)" the chance to start a real business. Without direct selling, few of us "commoners" would be able to afford the start up costs of a business or franchise. I am concerned that the proposed 7-day waiting period, litigation reporting, earnings claims, and requirement for "references" are impractical and will place an undue burden on existing distributors. So many prospective distributors are just like me when I began in this industry - they have a need and a dream and are hoping that, maybe, the company they are considering will be the answer. What I have found during my years in this industry is that the willingness of the individual/new distributor to actually WORK to make their dreams come true is far more relative to his or her success than the "legitimacy" of the company. Unfortunately, in our "have it now" society many people want to get rich quick and don't acknowledge the actual work that getting rich requires. This problem, however, should not be attributed to the direct selling industry but rather to the individuals who feel they've been short changed. Perhaps a disclosure about the fact that "this is a BUSINESS" should be required, but not things such as litigation reporting (which I understand does not even distinguish between winning and losing lawsuits). In general, it seems that the FTC in these proposed regulations is unfairly targeting direct selling businesses. I hope that you will not implement the various requirements I have referenced. Thank you for reviewing my comments.