|Received:||6/22/2006 5:07:35 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Hello to the FTC, I have reviewed the proposed Business Opportunity Rule R511993, from my perspective of over 10 years operating a Home Business on a full time basis. While I can certainly appreciate the intent and spirit of the rule's conditions, I can speak with total certainty that this rule in present form, will not help prevent the problems you are striving to prevent. It will instead, simply make it much more difficult for good business to be done. Specifically, the 7 Day "Wait" rule will kill most of the sponsoring (introducing a new person ready to go and get moving) activity, simply by breaking their emotional momentum. Additionally, when we travel, if there is a 7 Day Wait and we aren't there 7 days later, that person simply cannot be effectively trained during the most important part of their start up. RIGHT THEN while we're there. Other parts of the rule, having a list of geographically close participants, raises several serious issues. Privacy for one. Who wants their name and information "mandated to be revealed" by a company to someone "looking" at the business? I also raises other concerns, such as "Oh ... I didn't know THEY were in this business. Perhaps I WON'T JOIN because I never liked them." or of course just the opposite and instead, they decide to join THAT person on the list even though that person never contacted them and did none of the work to introduce this person. Revealing all litigation, without revealing the outcomes, another poor rule to have in place. What is the point? All these things do are to create suspicion, fear, stand in the way of the only thing they are after ... getting going. Having clear refund policies ... absolutely. Clear income or earnings statements backed by data, certainly. But to require all this documentation, supplying names, dates, lists, simply doesn't serve the purpose and instead, just adds to the cost and time to operate a business and puts a greater and greater burden on businesses. I know there are other provisions and I've read all of them. To be totally frank and brief at the same time, any that require participants in any of these businesses to dredge up 10 years of data that has no relevance to the business they want to do other than to say, "Look ... there are people who didn't want to do this or didn't succeed." or makes them wait, or casts suspicions simply because they can't know all the facts involved in those PAST ISSUES or forces them to BECOME one of those people on a list that must be revealed ... are all poor choices for helping "protect" us from business. The good companies all have very generous cancelation and buy back policies, already heavily "police" the ranks for making undue and unwarrented income or performance claims and are quick to assist anyone in being moved to a better sponsor for help when needed. Please do NOT ADD TO THIS with more rules, more paperwork, more issues. Thank you for your time and consideration.