Comment Number: 522418-04838
Received: 6/28/2006 3:39:29 PM
Organization:
Commenter: Rebecca Fujikawa
State: HI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Thank you for the opportunity to comment on the current proposal 16CFR Part 437. As a small business owner of more than one business, one of which is in conjunction with Quixtar as an Independent Business Owner (IBO) I find a few areas of concern with the proposal. 1) Providing prospects with names, addresses, phone numbers of other IBO's. This is an infringement of privacy. In today's world of identity theft, as well as all manner of physical ill will attempt possibilities I believe this opens a door for those looking to commit crimes. In my experience as a prospect I was introduced to other IBO's immediately. Subsequently with my own prospects my goal is to introduce them to other IBO's as quickly as possible to provide them with support and further knowledge. Again in my experience, at all times an IBO is aware, as I was made aware, they have the right to cancel at any time. I discourage a prospect from registering/beginning his business upon seeing the business plan the first time but have always suggested a second meeting to allow them time to go over the information, investigate via business channels such as yourselves, the BBB, and other viable resources. As any business decision would be so weighed and investigated. 2) Providing a list of lawsuits, arbitrations, legal claims. How about lets start where this would do the most good, the medical profession. How many lives would be spared if Doctors were required to provide prospective patients with a list of litigation or complaints by former patients? That'a information those prospective patients need to know, their lives depend on it. Yet we don't require that. If a business is operating illegally shut it down. Don't pass off the responsibility of doing your job by saying we showed you how many lawsuits and bad things but it was your choice. 3)Providing prospects with personal financial information. Again, this is obviously an infringement on peoples rights and puts them in a position of vulnerability with regard to theft and many other illegal acts. Also, income or success, with individual businesses, will be based upon each individuals work habits and effort. I would like to add that the people I have come in contact with in this business have never baulked at proving their income if the showing of that was in an appropriate setting. I do not advertise nor freely discuss my financial information for ANY of my businesses with anyone outside of my personal financial advisors and my tax professionals. Again thank you for the opportunity to give input on this proposal. Illegal operations should be identified and reprimanded or shut down as necessary. However infringing on the populace as a whole to identify a handful of immoral individuals does not seem correct. And I think that is the problem. In any occupation there are moral and immoral individuals. It is typicall the few bad apples that ruin the crate. As I stated here, I believe there are more pressing occupations that would benefit from some of these proposals. My experience as an IBO with quixtar has always been based upon full knowledge of my rights and potentials based upon my efforts. I have been allowed full access to any individual or information I requested without such laws being in place. To mandate the giving of such information puts us all in a position of having this information used by others for illgains.