|Received:||6/28/2006 5:08:39 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been Independent Business Owners (IBOs) affiliated with Quixtar & the Alticor companies for over 10 years. My wife, in addition, is an independent distributor for Stampin’ Up, for the past year. We have been able to supplement our single-worker income for our family of 6 with these home-based businesses. We have had the chance to share these opportunities with others. We’ve had only positive feedback and experiences. Specific to our affiliation with Quixtar, we’ve found the Alticor corporation to be most upfront with all information about incomes, complaints and dispute resolutions, refund policies, registrations, and every other facet of the opportunity. Many of the people we have introduced are simple consumers of their products and services. Others have decided to form their own independent businesses. Regarding the 7 day waiting period, I do not think this is necessary or even a positive suggestion. Certain products and services are available to IBOs and distributors at lower costs than to the general public or a customer. Delaying the ability to register your new business will end up costing the ‘prospect’ more, eliminating the chance of savings through commissions; and for those opportunities, like my wife’s Stampin’ Up, whose business is mostly done at home based parties, not allow these new ‘distributors’ to capitalize on their income ordered on the night of their first retail event. Not only would this hurt my business, but would hurt, not protect, the new prospective business owner. An alternative suggestion - A full refund should be required from any new business opportunity, such as ours, for protection of pressure-sales, or buyer’s remorse. The next proposal, requiring a list of references is not a good idea, or even practical. I am always happy to introduce prospects to other IBOs. With the federal and state privacy laws, regulations, policies and general concerns in today’s world, I cannot give out details and contact information about other IBOs. This would require that my _new_ prospect allow me to share his/her information in the future with anyone as well. This rule protects no one and violates everyone involved. The litigation list - It is difficult enough for any corporation, politician, or organization to operate in the interconnected world of the internet without baseless charges against them. Libel/slander laws, and simple fact checking help everyone’s name and character from being disparaged on the internet. If you proposed a law that said all ‘brick&mortar’ retailers must put a large sign on their front entrance with the same information, ‘Target’ would instantly have someone make multiple accusations against ‘Wal-Mart’ so that the information would have to be posted in front of each Wal-Mart. Litigation information is easily found online. Companies have their own “about us” page to discuss and respond. That is where this should be left. Finally, the requirement for financial substantiation. I’m not sure how this helps. In many cases, I’d love to be able to show a prospect what I’ve made. But, how does that help them? Am I not then saying – “You can make this much as well!” I do not show my income, but I describe in detail what incomes are available at what levels of success. I would think many IBOs and other home-based businesspeople could find a very successful partner or associate to show a prospect the ‘big-bucks’. I think this does the OPPOSITE of the FTC’s desired effect. Not to mention that a government requirement of disclosing your income to others is ludicrous. Wouldn’t a similar requirement be for all employers to disclose to a potential employee his/her manager’s income, and that person’s manager’s income, up to the CEO? That way a prospective employee would know what he/she ‘could’ earn by taking that job opportunity. It will not work. I think the FTC, if anything, can require that all income can be reached. Thank you.