Comment Number: 522418-09447
Received: 7/14/2006 2:59:57 PM
Organization: Xango
Commenter: Naruishi
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I've recently started our Xango business with my wife. We were very excited about the simplicity of the product, transparent organizational structure and the prospect of growing a home based business. My wife is pregnant and is due sometime in August. She is excited to build our Xango business from home and be with our first child. The FTC's intent to prevent fraud is commendable. However, there are many provisions that prevent honest businesses, like Xango, from being of any use to people like us trying to build a legitimate business. The provision for providing 10 referrences to prospective members could literally slow business to a halt. It is impractical and unwieldy for people starting out, like ourselves. Also, there are security issues of privacy and ID theft that are to be considered as well. The other impractical provision is the 7 day waiting period. This can bring doubt in the mind of potential customers and cause unnecessary delay. Record keeping and other administrative burdens are also increased. This increases the cost of doing business as well. As, I have mentioned before, we like the Xango business because of it's simplicity. It allows us to develop our business at any pace we want and most importantly allows others who sign up under us to develop as fast as they want. I understand and appreciate the FTC's efforts to stop fraudulent businesses. However, some provisions are just too impractical to allow legitimate businesses to thrive. Please reconsider your proposal to protect legitimate home based businesses like ours to thrive and provide us the opportunity to live out our dreams. Sincerely, Koichi Naruishi