| Comment Number: | 522418-09506 |
| Received: | 7/14/2006 4:53:27 PM |
| Organization: | N2K Trading Academy |
| Commenter: | Rose Sanford |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
July 14, 2006 This Letter is in reference to the proposed NEW BUSINESS OPPORTUNITY RULE R511993. The FTC's main focus is to protect the public from unfair and deceptive acts or practices. In relation to this new proposed ruling it will be extremely difficult for any direct selling company to stay in business. The seven-day waiting period to enroll new Distributors in N2k International (Trading Academy) will be a hardship. If I purchase an Automobile I donot have this waiting period. It is extremely unfair to impose this seven-day process on N2K associates. We have the option to sell products such as telecommunication services, Petroleum products that allows the consumer to save on their gas and prolong the life of their engine etc. Why would you impose a seven-day waiting period on some companies in the Direct Selling Industry and exclude others? Why? Because this ruling is very, very very, UNFAIR TO ALL COMPANIES in this industry. My perspective regarding the release of any information in relating to prior litigation and civil or criminal legal actions involving misrepresentation, or unfair or deceptive practices i.e., what if the company is found innocent of all charges apparently this does not matter. Any company or anyone can be sued for almost anything. Why should this be an issue unless the company was found guilty of the charges. Under the proposed elimination of the threshold N2K International's plan would fall under the FTC regulatory authority since the existing 500 Thrrshhold will be iliminated. they will then be responsible for producing numerous pieces of documented materials in order to comply. Extremely time consuming and costly. The Earning Claims requires direct sellers to gather information in relation to time period, demographic data and earnings cluams. This approach will be ineffective in preventing the targeted business opportunity fraud, since those perpetuating fradulent business opportunities will not provide accurate data anyway. In conclusion, I are uncomfortable giving out the personal information of individuals without their approval to strangers. This may result result in lawsuits. In order to provide the 10 prior purchasers, we will need to obtain the address of the prospective purchaser, search our database for the geographically nearest existing N2k Associates. People are very concerned about their privacy in this age of identify theft. The Federal Trades Commission is complimented on your effort to protect the consumers but the proposed new rules I believe, has many unforeseen consequences that may destroy my business. I am certain that there are other alternatives that would accomplish the consumer protection goals. I am forwarding this letter to my congressman and Senator. They need to know what voters are experiencing in the workplace under the government regulated officials to whom we also depend on for protection and fairness in relation to Small Business Environments. There are millions of us that will be adversely affected if this ruling is inacted. Thank you for your favorable consideration of my comments. Sincerely, Rose Sanford N2K International Associate