Comment Number: 522418-04760
Received: 6/28/2006 10:17:38 AM
Organization: Cook and Associates, Inc.
Commenter: Catherine Cook
State: OH
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

We have been building our business for 10 years. I have been able to replace my income as a parttime physician to stay at home with our two children and send them to the private school of our choice, which would not have happened if we did not pursue this business opportunity. Imposing a seven day waiting period would dissuade many people from taking part in this great opportunity--I know it would have in our case since people are busy and are most excited about anything at the time they have fresh facts in their minds. Disclosing exact income levels would not be a true representation since results for everyone vary somewhat based on their level of ambition. We provide people ranges and give them the ability to calculate through a computer program what their bonus would be if their group was built in any hypothetical configuration. Providing references of other IBOs in the area is similar to having every consumer in the U.S. who wants to buy gas at a B.P. station first call Shell and Citgo to see if they should shop at B.P. If the purpose of this provision is to have IBO's unsolicited opinions of the business, Quixtar has already provided that with thisbiz.now and testimonials from IBOs posted on their website. In my opinion, these provisions are being proposed to protect the consumers from misleading or misrepresenting claims. We have always promoted personal responsibility and have encouraged open communication about all aspects of our business and have had no problems in this area. Although I realize there is a certain amount of consumer protection that needs to occur, there is very little financial or time risk that occurs with this business model. In fact the Corporation (Alticor) and we as an incorporated entity, Cook and Associates, Inc. have promptly refunded people's money if they feel they have made a hasty decision and in some instances bought back products they have purchased. Imposing any restrictions on people's ability to make an informed decision starts to impose on their rights to own and operate a business of their own and fuel our economy with free enterprise. State laws (at least in Ohio) give people a three day grace period to change their mind about any transaction they have entered into, so that is already covered. Direct selling should not be discriminated against and treated any differently than other business ventures. Because of the income through this business, we have been able to start other businesses and provide work for many area contractors and others necessary to run our other businesses which contributes locally to our economy. We have given local conference rooms business due to the income from this business. We have held charity events, improved the health of the community, and we have come to the aid of local causes. I am certain the restrictions proposed would hamper this tremendously. Please consider these as you create policy. Also, please contact me if you would like further input on how to deal with these issues. I appreciate what you are dealing with and thank you in advance for your consideration. Sincerely, Catherine Cook, MD Independent Business Owner