| Comment Number: | 522418-11097 |
| Received: | 7/17/2006 2:09:18 AM |
| Organization: | |
| Commenter: | Kent Nabarrete |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-11097.pdf Download Adobe Reader |
Comments:
RE: Business Opportunity Rule, R511993 Dear Sir or Madam: I am urged to write this letter because of a personal business concern 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 literally destroy my small business even as I am starting to develop the business. I have been an independent home based business Distributor for several years since 1993. I originally started my Network Marketing business because of the products which I truly believed to be of benefit for myself, family and others. I loved them, which is what got me started in the business, and I saw the great potential to earn some additional honest money. Within 30 days, I will be retired and my present income will not exist, and worst yet, my family fully depends on this potential business income to provide a great portion of our retirement income. Please don’t allow this unnecessary Rule to destroy our small business!! We need it! As I reviewed the proposed rules of the some of the sections, I became quite concerned that these very same rules would make it virtually impossible for me to sell my product and engage others to do the same. I believe the seven-day waiting period is totally unnecessary. The waiting period will give the public the idea that there’s something wrong with me, or our plan, or even the folks who provide me support, which reflects badly on me, and questions my integrity. XanGo already has a 100% buyback policy for its one single product. One of the most difficult sections of the proposed rule is the seven day waiting period to enroll a new Distributor. 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 need to keep very detailed records when I first speak to someone as a prospect, and will then have to send in reports to my company. I am a small home business consisting of one person, and this burden will hurt or destroy my business. This proposed rule is actually anti-small business because of the additional burden it creates. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad 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. Potentially women who join 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. I have seen many scams on the Internet, been approached by many questionable characters, and in the past I have been a victim myself and “taken” by unscrupulous people who think nothing of taking money from good people. This rule will do nothing to stop them because they are not only smart in going about their immoral business, but create schemes to make a quick dollar, then disappear. This rule will not stop Crooks – crooks continually violate the current rules and laws all the time because they have no morals. But I am a good American citizen and it will hurt me, and it will actually hurt my honest business! Thank you in advance for your favorable consideration of this request. Sincerely, _____________________________________ Kent S. Nabarrete Independent XanGo Distributor