| Comment Number: | 522418-10856 |
| Received: | 7/16/2006 11:17:15 PM |
| Organization: | Self and NVI |
| Commenter: | Edgar D Short |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
This comment concerns the "Businiess Opportunity Rule" as stated above R511993 Dear Federal Tade Commission or to whom it may concern, I have had a home based business part-time since 1996 and have realized financial and product benefits without any dishonesty or mischief at all by me or any of my customers. The most important thing that our business has done for my family is supplied us with one of a kind products. The extra income is very important too. We got into direct sales by referral and have become better people for it. Our company has helped me overcome bad habits and get into personal development that I've passed on to younger people for the better. I'm in the process of building my confindence through our company to do presentations and speaking. So, the legitimate, good companies offer many benefits besides sales and products. I know that there is dishonesty and mischief in any type of business and I realize the good things that the FTC is trying to do. However, it is imperative that provisions do not prohibit or harm credible, legitimate direct sales companies. There are countless reputable small home based business owners counting on the income to make ends meet. Many have sustained growth and plan on future growth. Millions of people have felt the positive effects of legitimate direct sells companies. The growth of small home-based direct sells companies is very important to America and it's tax structure. Direct sells companies are small businesses vital to America's economy. Please reconsider the following provisions: 1) The Seven Day Waiting Period:This provision cast the industry in an unfair way. No company that I know of has a seven day waiting period especially when it only concerns $500 dollors or less. Not even the Time Share industry has a seven day waiting period. The direct sells industry as a whole is legitimate and honest. By my observation far fewer fruadulent companies exist in the direct sales industry compared to the general business world (corporate, etc). This provision unfairly targets legitimate direct sells companies and the industry. 2) $500 Business Threshold: I think that this provision will force me to comply with other provisons more appropriate for bigger companies requiring much higher investments. I think that this provison would create undue hardship on the majority of the home based businesse like mine. 3) Litigation Reporting Provision: Why would anyone or any business by all rights have to report all litigation regardless of win or lose. Doesn't win mean non guilt? Isn't there some rights issues here? Reporting of all litigation is irrelevant and unfairly targets the directs sales industry. Meaningless law suits are just what they imply "meaningless". They shouldn't serve as unwarrented red flags for my prospects. 4)Earnings Claims:This provision will not stop the guilty targeted people. Over zealous earnings claims will go on anyway. Our company discourages earnings claims. In some special cases everyone knows that the claims are true. In other cases necessary data would be very difficult if not impossible to collect. Privacy issues? 5)Finding The "10 Nearest Existing Sales People": Finding the 10 nearest existing sales people would be like being a private-eye because this involves privacy issues. It would be impractical to do this during the coarse of everyday business. Privacy issues with some people would put my business in a liability situation. This would be an unwarrented red flag and undue hardship on any new business. This provision will undoubtly target the direct sales industry. I thank you for the opportunity to express my feelings and concerns...Edgar D. Short