| Comment Number: | 522418-13112 |
| Received: | 8/7/2006 8:11:26 PM |
| Organization: | CONSUMER AWARENESS INSTITUTE - AND PYRAMID SCHEME ALERT |
| Commenter: | JON TAYLOR |
| State: | UT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-13112.pdf Download Adobe Reader |
Comments:
As president of Consumer Awareness Institute, and Advisor to Pyramid Scheme Alert, both non-profit organizations that specialize in preventing and exposing pyramid scheme fraud worldwide, I offer the attached rebuttal of comments by the Direct Selling Association (DSA), comments numbered 522418-12055 through 522418-12096 by Joseph Mariano. Headings for key points discussed in the attachment include: Qualifications of this analyst, Dr. Jon M. Taylor (and request for a hearing) The Direct Selling Association, recently taken over by chain sellers, now promotes chain selling (pyramid marketing) - even more than legitimate direct selling. Using the "5 Red Flags" analysis of compensation plans, the harm in chain selling, or pyramid marketing schemes, can now be identified, and such schemes (many of them DSA members) can finally be clearly differentiated from legitimate business opportunities. The DSA lumps together legitimate direct selling with chain (pyramid) selling, which meets the technical definition of an illegal pyramid scheme in most jurisdictions. Using deceptive tactics, the DSA lobbies to legalize blatant chain (pyramid) selling. The DSA appears willing to engage in any deception to further its ends - including the web version of ID theft. The DSA and DSA member firms have mobilized their massive lists to get participants to write in their "concerns" and objections to the proposed business opportunity disclosure rule - based on templates or form letters supplied by the DSA or member firms or consultants. DSA data and arguments are so highly questionable that most of their input should be discounted in developing a meaningful business opportunity disclosure rule. Specific rebuttals of DSA points (Detailed arguments are in the attachment.)