| Comment Number: | 522418-12362 |
| Received: | 7/17/2006 8:54:18 PM |
| Organization: | |
| Commenter: | Robert Sibbald |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Comments on ''Business Opportunity Rule, R511993”. My wife and I were introduced to direct sales through a radio advertisement about one year ago. The product and company exceeded my expectations in quality and excellence of operations. As a result of this experience we have chosen to share with others what was shared with us in the form of a business opportunity and quality product that has helped with health concerns and addressing retirement financial shortages by allowing us to create residual income to offset poor planning on my part. As we have gotten older this has been a very deep concern and we have been so thankfull to have been given a way to progress through older years with dignity and a sense of security. It takes discipline and hard work to find and train a team but this is the way of most things of value in life. Personal developement to equip and train my team is an ongoing process but spills over to other areas of our life that increases value in other peoples lives as well. The suprising thing is that the same skills that are required for success in direct sales are the same skills for church leadership success. It is understandable and appreciative for FTC's consumer protection as nobody wants to be taken advantage of in a fraudulant manner, however regulations can place a heavy burden on legitimate business while providing a false sense of security to the public. Those with fraudulent intent will cover there activitys with false information that can set the stage for public due diligence to rest upon the protection of the regulations. If the information has been provided falsely, consumers have only been given a layer of false security to rest there decision on. Waiting seven days to join seems to cast a dark cloud on direct selling that is out of proportion with the amount of consumer risk and would greatly hinder legitimate direct selling by arousing undue suspicion and cause prospective purchasers to possibly miss a product or opportunity that would help them. Removing the $500 business threshold, litigation reporting, earnings claims, and providing a list of references becomes very burdensome and will discourage prospective purchasers because of not wanting to go through the red tape involved. This hinders legitimate business development and does little to hinder those that would be fraudulant as false information is can be provided and public sense of security given another layer to be deceived from. Thank you for your time.