| Comment Number: | 522418-04515 |
| Received: | 6/27/2006 8:56:36 AM |
| Organization: | SL Global |
| Commenter: | Sarat Susarla |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sirs: I am sending this email in regards to the proposed "Business opportunity rule". I am a business owner and a physician living in Houston Texas, currently developing my business in affiliation with Quixtar.com. I was exposed to this opportunity approximately 14 months ago. I have been actively building my business since the past several months. My exposure to this business opportunity was through my brother in law, who gradually introduced me to other business owners and business concepts in general. I would say that my knowledge of business has always been limited, but it continues to grow with my association with other independent business owners. Judging by your proposed rule, i would say your intention to inform the public about fraudulent business practices is a good one, but the means by which you propose to do it will be ineffective. First, this 7 day waiting period is unlikely to provide any measure of security. In our business, we see people that take a few days and some that take many months to understand how to become successful. These time restrictions, however, are likely to significantly impair our ability to grow. stifling the momentum associated with rapid growth and enthusiasm of new business owners. The issue of providing references of local IBOs to new business prospects i find very puzzling. IBOs do not advertise in TV or newspapers. What then, suggests that it is ok to distribute names and phone number of these people so easily. Is there not a significant privacy issue here? Also, what prevents these other IBOs from signing these new prospects that contact them. It effectively destroys the work and efforts of each IBO whose largest asset is his network of contacts. I believe the type of restrictions you are intending to impose should be directed at direct selling organizations that have demonstrated poor business practices. Quixtar, however has been exemplary in policing itself and IBO members by requiring a strict code of IBO conduct. It reserves the right to deny the rights of affiliation to those who violate these practices. I believe close examination of these proposed policies as well as the strict ethical codes in the Quixtar business model will show that these proposed rules are unreasonably restrictive and will unlikely accomplish their attended goal. Alternatively, if such rules pass, then fairness dictates that all large and small business should be restricted in a similar way, which i believe, is ridiculous. Sincerely Sarat Susarla, M.D.