| Comment Number: | 522418-10191 |
| Received: | 7/15/2006 10:05:10 PM |
| Organization: | XanGo Independent Distributor |
| Commenter: | Bethany White |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
In Response to the proposed “Business Opportunity Rule, R511993”, I would like to make a few comments about how this would affect my business. I appreciate the great efforts made by the FTC to protect the public, myself included, from the many fraudulent business scams that are out there. I would, however, like to bring to your attention the detrimental affect this rule would have on, not only my business, but the direct selling industry in general. While I understand the necessity of this rule to protect people against losing large amounts of money in a franchising opportunity, I do not see the need for these requirements for someone investing $35 dollars in a business opportunity like mine. In fact, that small amount of money is one of the most appealing aspects of the direct selling company of which I am a part. To remove the $500 threshold would unfairly place my company, with its $35 start up fee, in the same category as a $250,000 franchise. Much of my business is reliant on the excitement and initiative of new prospects. Both of these would be reduced quite a bit by the seven day waiting period proposed in this rule. Quite often new prospects use the first week after sign up to tell their friends and loved ones about their new business. If forced to wait seven days before being enrolled, new prospects would lose quite a bit of the excitement they originally had about our product/company. On top of that, there would be an added element of skepticism about the legitimacy of our product/business that does not exist now. Another aspect of this rule that would create difficulty for my business is the requirement of references to all new prospects. My business consists of 259 distributors in 24 states and 2 foreign countries. Requiring me to provide new prospects with the information of the “10 nearest existing sales people” is quite impractical since I don’t know where someone lives until after I have met them. Also, asking me to disclose my personal contact information, as well as the information of hundreds of thousands of other distributors for the company would be placing our security at risk. This information would not only be available to true prospects, but also to competitors who would act interested only to obtain the contact information of distributors to use dishonestly. This would only succeed in furthering the already rampant threat of identity theft. Thank you so much for letting me voice my concerns, and for taking the time to read this! Sincerely, Bethany White