|Received:||7/17/2006 8:45:47 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am a Unit Leader with Creative Memories, a direct selling organization whose mission is to preserve the past, enrich the present, and inspire hope for the future through memory preservation. I am concerned about the proposed Business Opportunity Law because I believe it would have a serious and detremental impact on my small business. Like most Creative Memories consultants, my business is small (gross sales under $30,000 per year.) Most of us are part time. We love our businesses because we love helping people organize their photos and tell the stories of their lives that will live for generations. Most of us aren't in it to make a lot of money, in fact, many of us really struggle with the business and paperwork aspects of our jobs. Having an upline, or someone who helped you enter the business is so crucial in helping you to get going. With the additional paperwork, time, and potential confusion that the Business Opportunity Law would require, many Creative Memories Consultants would never try to help someone else begin a business of their own. I understand the intent of the law as one that woud help protect people from investing a huge amount of money into a losing or impossible business. I can certainly see the need for the kind of disclosure statement and waiting period if someone was going to buy a franchise or invest thousands of dollars. With Creative Memories, our start up cost is only $195 plus tax. The disclosure statement and waiting period could be so burdensome that many of us would stop recruiting. Also it could make potential recruits think this business is much more complicated and risky than it is. I hope my feedback and the feedback from other direct sellers will convinve you that the Business Opportunity Law is going too far, especially for small, low dollar businesses such as mine.