| Comment Number: | 522418-09310 |
| Received: | 7/14/2006 11:05:58 AM |
| Organization: | Vitamark International |
| Commenter: | David Cutter |
| State: | VA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear FTC: At the age of 19 I was first involved in network marketing (mlm) - at the age of 26, I am still involved. While I have cannot claim to have hit "financial freedom" just yet, I can say that the business has altered my life in many ways. From introducing me to personal development (a MAJOR part of our industry) to friendships to enjoying some of the finest nutritional products in the world, the nature of the network marketing business model is one of the finest opportunities in the world for any US citizen to start a part time business and provide themselves the opportunity to earn a passive monthly income. Sure, people lose money, people drop out, people have negative experiences - but that happens in any business from real estate to insurance to franchises. I understand and appreciate the FTC's interest in protecting the people, but the thing is the bad apples will not comply with the rules anyways. And given that the general public will not be aware of the regulations, people will still fall prey to all sorts of frauds and schemes? I could quote references to our great business model by many - from former President Bill Clinton, the great Wall Street investor Warren Buffett, the prized economist Paul Zane Pilzer, and many other business tycoons and authors praising the Direct Sales / Network Marketing industry for what it brings to the table from an entrepreneurial and economic standpoint - but I'm sure many others will provide those references to you. The negative effects that some of the proposed regulations could have on our industry could have a negative rippling effect much wider than just protecting a few "innocent victims." This could eliminate one of the greatest business models for the everday entrepreneur (from house wife to executive level professionals), severly impacting many other stakeholders: - publishers of books, tapes, CD's, DVD's that work with the millions of distributors worldwide - MANY suppliers of raw ingredients, packaging, and other aspects of the production value chain for the billions of dollars in products that are moved through a variety of industries each year using the direct sales model - hundreds of thousands of employees whose jobs depend on the financial health of these companies - millions of shareholders of public companies that employ this method of sales and marketing I sincerely hope that you listen to the Direct Sales industry, the DSA, the DRA, and the many companies and independent contractors whose livelihoods depend on this business. The potential downside to these proposed regulations goes well beyond the positives of trying to help people make better decisions. Sincerely, David Cutter proud Independent Distributor of Vitamark International