| Comment Number: | 522418-10642 |
| Received: | 7/16/2006 7:49:14 PM |
| Organization: | Blue Green Wellness affiliated with Cell Tech International |
| Commenter: | Margaret E Dexter |
| State: | TN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am concerned about the proposed Business Opportunity Rule for several reasons. (1) As a single woman working out of my home, the idea that my contact information could be given to anyone in this area who is - or pretends to be - a prospect is a major concern. This strikes me as a very bad idea. Lists of distributors in MLM companies is confidential information. We are very careful to protect this information to prevent people from other companies from prospecting our members. Aside from that, this is an invasion of my privacy and is potentially dangerous to me. (2) I agree that pyramid schemes should not be permitted, but it is my understanding that you have ways of prosecuting those who are not ligitimate MLM companies. It seems that you are placing a very unfair burden on the legitimate companies in an effort to stop those who are not legitimate who will probably just lie on the disclosure forms anyway - if they are not telling their prospects the truth, why should they tell you the truth? (3) I believe that good rules could help the MLM industry just as regulation years ago made francises acceptable business opportunities. But I think this rule has some very bad features evidently based on lack of understanding of how the good companies work. This is understandable since you probably only have contact with the bad ones, but please don't penalize the companies that have excellent products and distributors who work as their sales force. This is an important segment of the economy that does not need to be depressed by punitive rules and reporting requirements. I have been affiliated with Cell Tech International for over 10 years. I don't make a lot of money, but I do get a check every month and have since the very beginning. It is an important portion of my income, supplementing my social security check each month. I am able to work when if and as much as I want to, and my efforts determine how much money I make. Cell Tech is integrity - I've never had any contact with a company that does such a good job of making sure that what they do and the way they do it is totally in integrity. But I can see that some of the requirements of this rule could cause them a lot of time and expense. Please review this rule, take a good look at the good MLM companies and how this would effect them, and give us a ruling that supports the grown of letitimate companies and the business of those of use who are distributors for those companies. Thank you, Margaret Dexter