| Comment Number: | 522418-10599 |
| Received: | 7/16/2006 6:37:57 PM |
| Organization: | Xango |
| Commenter: | Brooks Walton |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) Re: Business Opportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing this letter because I am concerned about the proposed Business Opportunity Rule R511993. I believe that in its presented form, it could prevent me from continuing as a Distributor with Xango and destroy my small business. I started in network marketing in the early 80’s. I became a Mary Kay consultant. I tried the products, loved the results and with a little further investigating on my part, decided to do it as a business. It was a minimal financial investment. The business model fit into my family schedule, part time from home around my children and it would still provide a little income for the extras that a growing family needs. It was an ideal fit for me. I brought in a small but steady income. My experience with Mary Kay was invaluable. I was introduced to the world of direct sales and network marketing for the first time. And I loved it. I was very proud of my accomplishments. I was at home and helping with the family budget. In the mid nineties, I became involved with another network marketing company, Melaleuca. I was introduced to the products, again liked the results, again researched the company and again with a minimal investment decided to pursue a business with this company. It provided a nice supplemental income for our family that we did count on. I have now become a distributor with a company called Xango. My children are now grown, my baby is finishing her last year at college. And, my family can still use the additional income, only this time to help supplement our retirement. I have not gone from one company to another in the network marketing industry, I have not fallen victim to get rich quick scams. I have researched and studied and have chosen only three companies, one at a time of course. The supplemental income to our family most helpful and I could still be home with our two children. Some of the sections in the proposed rule would make it hard or almost impossible for me to sell my product. This waiting period will give the public the idea that there’s something wrong with me or our plan. I think it would reflect badly on me. I also think this seven-day waiting period is unnecessary. Xango’s sales kit only costs $35. People buy TVs, cars, and other items that cost much more than that and they don’t have to wait seven-days. Under this waiting period requirement, I will have to keep very detailed records when I first speak to someone and will then have to send in reports to my company. I am a small home business and this burden will hurt or destroy my business. This proposed rule would be harmful to my business. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am most happy to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Women in my organization may be subject to sexual or racial harassment, so this part can’t go in at all, unless the FTC passes an addition to this rule Prohibiting sexual or racial attacks related to this disclosure. In the end, the rule must bind the FTC to take direct enforcement action on sexual and racial attacks with a special unit assigned to monitor actions related to the disclosure forms. While rules are important, I think this one needs to be revised. My home business is important to me and to my family. We do rely on the supplemental income. Thank you and I appreciate your time and attention in reading my letter.