Comment Number: 522418-09460
Received: 7/14/2006 3:31:57 PM
Organization:
Commenter: Fred Brashear
State: TX
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

July 14, 2006 FTC, Office of Secretary, Room H-135 (Annex W) 600 Pennsylvania Ave NW Washington, DC 20580 RE: Business Opportunity Rule R511993 To Whom It May Concern: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it would prevent the business I operate from continuing as a XanGo™ Independent Distributor, and would destroy the small business I have worked so hard to build and operate, as well as those of, literally, thousands of others. I have been operating a home based business, which is an independent Contractor representing XanGo™ LLC, for about 18 months. Some of the sections in the proposed rule (Rule 511993) would make it hard or almost impossible for me to sell the XanGo™ product and would make it especially difficult, if not impossible, to introduce others to this fantastic opportunity under the proposed rules. Changing to the new rules would devastate the growth and profit potential of the business I operate. The proposed waiting period will give the public the idea that there’s something wrong with me or the XanGo™ business plan and also will reflect badly on me. I believe this seven-day waiting period is unnecessary, because XanGo™ already has a 90% buyback policy for all products including sales kits purchased by a salesperson. Additionally a 100% total money back guarantee can be exercised by anyone purchasing from XanGo™ within the first 30 day period. The current procedures in place by XanGo™ already insure that no one can ever be hurt financially by the XanGo™ business opportunity. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new distributor. The procedures associated with the proposed rule change would make it, literally, extremely difficult to build and operate a XanGo™ business. This change would stifle the initial profit and actually make operating a XanGo™ business less profitable than it currently is under the existing rules and procedures. For a new rule to stifle profit should point out the inadequacy of thought that has generated this new rule proposal. Under this waiting period requirement, I will need to keep very detailed records when I first speak to a prospect and will then have to send in reports to my company. This is an unnecessary burden to place upon my business. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I would be glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Also, sharing names and addresses of existing distributors with a “prospect” would open an organization to being attacked by other businesses. A person from another sales organization who wished to proselytize an existing organization would literally be given the key to the bank….it would be like hiring the fox to protect the hens in a hen house. The proposed rule R511993 will not stop Crooks – they violate the current rule all the time. But I am a good American citizen and the proposed rule R511993 will hurt me. Please insure that any proposed rules will not be detrimental to the incredible volume of sales created by the Direct Selling Industry, a Multi Billion Dollar industry today. To do so would hurt the United States economy tremendously. May I humbly suggest that you or your representative visit the XanGo™ LLC headquarters in Utah and see what kind of passionate and caring company this is? You will be shocked to see a company which has the hearts of the American People in their minds, and one that would never place an individual in peril financially. Please go after the bad guys, not the good guys. Most respectfully, Fred Brashear