|Received:||7/17/2006 5:15:17 PM|
|Organization:||National Association of Consumer Agency Administrators|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:In response to the proposed Business Opportunity Rule, the National Association of Consumer Agency Administrators (NACAA) recently conducted a canvass of its members to determine what problems, if any, consumers were having with direct selling businesses. Our members nationwide reported there was no appreciable number of complaints filed against direct sellers that are member companies of the Direct Selling Association (DSA). However, those same members reported that there have been for many years, and continue to be, numerous complaints regarding "business opportunities" and "work at home schemes”. These types of scams fraudulently prey on consumers through false promises of quick fortunes at little cost and little effort. NACAA has found through this latest survey that a joint effort underaken a number of years ago with the Direct Selling Education Foundation (DSEF) has borne the fruit of a much better direct selling marketplace. This is particularly true of the Direct Selling Association members who abide by its “Code of Ethics” -- a standard that is stricter than most of the current state laws. While we encourage and applaud rules cleaning up the “biz op” landscape, we would also recommend that any proposed rules take into consideration the changes that have taken place in the direct selling industry. We would urge that rules regarding direct selling be tempered so as not to adversely impact the changes that provide private consumer protections to the industry members and the general public as well. The National Association of Consumer Agency Administrators is the nation’s only consumer organization whose members deal directly with consumer complaints on a daily basis. Organized in 1977, NACAA members are front line public and private advocates who work with consumers to solve problems, prosecute offenders, advance legislation, and educate the public. NACAA currently represents more than 160 government agencies and 50 corporate consumer offices in the U.S. and abroad. The Direct Selling Education Foundation ranks among NACAA’s oldest corporate partners.