Comment Number: 522418-12750
Received: 7/17/2006 11:55:29 PM
Organization: Vemma
Commenter: Steve Hannesson
State: AZ
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

In regard to Business Opportunity Rule R511993, I believe the proposed regulations, in their effort to protect our citizens from unscrupulous companies, would end up hurting many ethical business people by casting a cloud of suspicion over everyone. I'm with a solid, ethical company that has a very liberal refund policy, no upfront start-up costs, and has never been late on a royalty payment. These rules, applied to our company and its distributors, will only hurt our business. Most damaging would be the seven day waiting period. This not only would cast a shadow of doubt about our company, but it would also cause a needless delay in getting our new distributors going in the business. We already have an "empty bottle" refund policy whereby any customer who is unsatisfied with our product can get a full refund even after using all of the product. Another hindrance to upstanding companies like ours is to require a list of 10 nearest purchasers. This regulation would cause all sorts of confidentiality and privacy issues for our customers as well as further prolonging the process of getting our distributors going in our business. As for the requirement of earnings claims, I believe that the very people these regulations are targeting are going to be the ones providing false information anyway, while causing legitimate companies more unnecessary paperwork. Overall, the implementation of these regulations would have a very detrimental effect on my personal business. As one who has nearly fallen victim to several scams in the past, I, as much as anyone, want to see people protected from scam artists; but these regulations are throwing the baby out with the bath water. I can see that they've been proposed with the best of intentions, but to see them implemented would also reveal a mass of destruction left behind in their wake. Thanks, Steve Hannesson