|Received:||7/14/2006 11:58:40 AM|
|Organization:||RETN for Wellness|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
|Attachment:||522418-09338.pdf Download Adobe Reader|
Comments:re: Business Opportunity Rule, R511993 The proposed ruling adversely impacts, actually effectively destroys, an entire industry when only a few 'bad actors' have created any problems. I have been involved in the direct marketing industry for many years. The companies that I work with are reputable and do not in anyway attempt to decieve their potential customers. Also, the rulings are not practical. They don't accomplish your purpose, strenghtening the return of goods policies to full 30-days of even opened or used items would be more effective in letting people recover their money if they were dissatisfied. The requirements for a 7-day waiting period would only prevent people from getting the products that that they want and need in a timely manner. Since most people who work with direct marketing companies are product users who want the discounted prices this would be a severe impact. Also, how can you evaluate a company without using their products or seeing their training kits? Requiring that a list of 10 product users in the area is also counter productive. With the privacy act and all the identity theft and no call lists it is obvious that if I told someone that their name and contact information would be distributed freely to anybody and everybody who wanted to join the company I would have not customers or distributors at all. In an age when every company is sending privacy policies through the mail to reinforce how they are protecting my privacy this rule is a double standard, asking the direct marketing companies to not respect your privacy. The distributor/wholesale buyer for most of these companies is a small business. The burden of the records and record keeping required would prevent anyone from participating. Isn't government supposed to be trying to reduce paperwork? And how many tax dollars will it cost to police all this? The financial investment in most companies is small. Usually less than $50 plus whatever products the person desires to purchase. When I joined Costco the fee was $100 for my executive membership. That membership gives me the privileges to buy at their reduced prices and gives me rebates on my purchases. You didn't require me to wait 7 days before I started to purchase things in their stores. The vast majority of people joining a direct marketing company treat their membership. Please reconsider the impact and the practicallity of your rules. If you want to protect the consumer, then do it in a way that will actually protect the consumer. Strengthen the return/refund policies, (some companies only allow return of unopened goods, how can you tell if these have value if you have never opened it.) Strengthen the sanctions if a company is found in decietful practices. This industry is very important to the physical and financial health of many, many people in the US. There are many good, reputable, ethical companies who are maintaining the industry. In every industry there are those companies who do not maintain a high standard of ethics. Don't destroy this industry because of a few 'bad apples' when your rules, as they are currently proposed, won't help prevent the 'bad apples'. Don't make a double-standard for this industry. Thank you for you reconsideration of this.