|Received:||7/15/2006 1:20:41 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Ladies/Gentlemen: I am deeply troubled by the potential impacts of Business Opportunity Rule, R511993, to my direct sales business. I am a very new distributor for XanGo. I was recruited by an honorable, decent person whom I trust completely. Let me say that I appreciate your desire to protect consumers, as I feel I benefit from those efforts. However, I do believe this rule may unfairly target legitimate direct sales businesses. *The seven day waiting period, for example, is impractical, causes unnecessary delays, creates huge record keeping and administrative problems, and casts all direct selling plans in a negative light. *Eliminating the $500 business threshhold forces most direct selling companies to comply with other provisions of the proposed rule which are more appropriate for businesses requiring a greater investment than a direct selling sales kit. *The litigation reporting requirement is unfair, in that it does not distinguish between winning and losing lawsuits. *Collecting required data for the earnings claims would be difficult, if not impossible. Furthermore, while the dishonest individuals you are targeting with this rule will predictably fail to provide accurate data, legitimate companies will comply. What good does that do any of us? *Providing references of the "10 nearest existing sales people" would not only be exceedingly difficult, it would also raise serious privacy and safety issues, as well as present dishonest scam artists with the opportunity for ID theft. It would also bring about tremendous liability issues for the entire XanGo corporation. I wish to thank you for working so hard to protect consumers in our country. However, I implore you to please seriously consider the dire consequences of Business Opportunity Rule, R511993 upon legitimate direct sales businesses before it is too late.