|Received:||7/16/2006 6:01:53 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am writing to oppose the stringency of guidelines that are being proposed for direct sellers. While some of the proposals are laudable, others will cause more harm than good. 1) You are proposing that we provide a list of 10 local references. This will violate privacy and open the door for problems. In addition, if I speak to an individual, and get him or her excited about building an independent business, but I have to provide references, that individual may then go to someone who lives closer, but is not within my same umbrella organization. I don't see that this aspect could be dangerous (as in violating privacy), but it would certainly be unfair. 2) If that person is excited now, and wanting to get started now, he or she could lose valuable time by being forced to wait 7 days before registering. On the other hand, in a business such as the one I am affiliated with, the 100% money back guarantee ensures that no one can lose money. I would suggest a waiting period be required for any company that does not guarantee 95% or more of the prospect's money back if not completely satisfied. 3) The requirement to disclose all legal claims for the past 10 years would probably cause far more harm than good, especially for legitimate companies that would actually obey the ruling. The more unethical companies would likely ignore the ruling, and continue to swindle and misinform people. Any ethical, legitimate company probably has many legal claims against it (depending on how long it has been in business), but not all those claims are themselves ethical or legitimate. This would be far too much for the average person to sort through, and look at objectively. Do you want a list of all the legal claims against a company like Johnson & Johnson any time you buy a product from that company? 4) Furthermore, being required to provide personal financial documentation is another invasion of privacy, and could prove to be very deleterious. It is none of my business how much money you make.