|Received:||6/26/2006 6:54:48 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar IBO for about 8 months and the rule you are proposing would seriously put a strain on my business. There has never been any mis-representation of income or get rich quick claimes that I have heard. Here are a list of concerns and recommendations for you to review. Concerns about the law • Prohibit prospects from registering as IBOs until seven days after they receive a disclosure document. • Require IBOs to give every prospect a list of “references” – contact information for 10 other IBOs in the area – seven days before the prospect registers. • List all legal allegations – lawsuits, arbitrations, and other legal claims – against Quixtar and its IBOs from the past 10 years. • Require IBOs to calculate and make different disclosures for every income claim. • Require that every prospect receive “substantiation” for every income claim. Our recommendations Quixtar and the IBOAI support reasonable business disclosures that are fair and help consumers make wise choices. In our view, here is what the rule Should and Should not do. The rule… • Should create a level playing field by requiring clear, simple, and standardized income disclosures that apply to all direct sellers. • Should provide a reasonable cancellation policy. Recommendations The rule • Should create a level playing field by requiring clear, simple, and standardized income disclosures that apply to all direct sellers. • Should provide a reasonable cancellation policy. • Should not require a seven-day waiting period before a prospect could register. • Should not require IBO references be provided to prospects or disclosure of past litigation. • Should not require financial records to be disclosed to prospects.