| Comment Number: | 522418-10741 |
| Received: | 7/16/2006 9:52:35 PM |
| Organization: | |
| Commenter: | Barrie Best |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I appreciate this opportunity to exress my concerns regarding the proposed Business Opportunity Rule, R511993 and the unduly negative impact it would have on myself and other honest and reputable colleagues in the direct sales business. I applaud the Commission for wanting to take action against unethical and unscrupulous people who have tainted our industry. However, the swindlers will only find ways around the regulations while the vast majority of direct sales business owners will be unnecessarily and unfairly impacted. I respectfully submit that the seven day waiting period is impractical and puts the direct selling business format in a very negative light, causing unnecessary delays and considerable record keeping and administrative problems. By eliminating the $500 business threshold the legitimate businesses will be forced to comply with provisions of the proposed rule that are more appropriate for businesses requiring a greater investment than a direct selling sales kit. The litigation reporting is most unfair as it does not distinguish between winning and losing lawsuits neccistating irrelevant reporting. With respect to earnings claims the bad actors will not provide accurate data whereas legitimate companies will. It will also be extremely difficult to collect the required data. Finally, besides the impracticality of finding "10 nearest exisitng sales people" privacy and safety issues come into play along with possible corporate liability for ID theft. Let me again express my appreciation for the Commissions concern for consumer protection against fraduulent groups as well as the imnpact on legitimate direct selling companies, but, this rule unfairly targets and negatively impacts the legitimate businesses.