|Received:||7/17/2006 1:55:33 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Proposed rule 16 CFR Part 437, while well-meaning, is overly broad and will cause a chilling effect and extraordinary hardship for legitimate home-based business. The rule effectively treats all such companies as shams and imposes overburdensome record-keeping which invades the privacy of new people. Ironically, my company helps people affected by the #1 problem of the FTC, identity theft, and the rule would effectively prevent people from accessing the service. Further, my company's service can help people evaluate opportunities by giving them liberal access to lawyers. Scam artists will continue to evade the rule, misleading people and running. Short-lived companies who run scams will ignore the rule and laugh all the way to the bank. Legitimate, well-established companies which involve ordinary people will be hamstrung. I work with a publicly traded company regulated by the SEC and many states, and the rule will treat my company as suspect. The rule should be more narrowly drawn, if passed at all, so as to protect the privacy rights of people, recognize there is a difference between legitimate and shady companies, and to prevent a home-based business persom from having to engage in sophisticated, up-to-the-minute record-keeping.