| Comment Number: | 522418-09960 |
| Received: | 7/15/2006 2:24:55 PM |
| Organization: | Vemma |
| Commenter: | Rich & Karen Rowe |
| State: | KS |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Federal Trade Commission: We have been in the direct sales industry for 26 years. We earn our entire income from direct sales. Over the past years, this industry has provided us with the most up to date personal training available anywhere. This industry has provided us the freedom to do volunteer work and reach out to our community. We appreciate that the FTC protects the consumer but we are concerned that legitimate small business owners may greatly suffer from additional onerous regulations. Specifically, the seven day waiting period would be impractical, cast the direct selling in a negative light, and cause unnecessary delays. We are concerned about the litigation reporting in that it does not distinguish between winning and losing lawsuits and the irrelevance of the reporting of almost all litigation regardless of the outcome. Regarding the earnings claims, it is difficult to collect the required data and, in addition, bad companies will not provide accurate data while legitimate companies will comply. As for the references, it is impractical to find the "10 nearest sales people", and privacy and safety issues would come into play with this regulation. Thank you so much for your time and consideration of this letter. Sincerely, Rich & Karen Rowe