|Received:||6/28/2006 8:22:16 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an Independent Business Owner affiliated with Quixtar since 1999 and before that with Amway since 1990. I have also been a Real Estate Broker since 1988. My wife and I are able to work from home with both businesses. When we registered in 1990 for Amway, we could see that it would take work to be successful just like it was taking to make it in real estate. We were given documentation about the sales and marketing plan AND a money back guarantee. Since that time we have learned how to be successful from home and we offer this to as many people as we can. We already do business ligitimately. We charge the standard sign up fee for Quixtar, which is approx. $51.50 and we encourage everyone to purchase an intro product pack for approx. $60 to begin to get comfortable with the product line. We are very interested in protecting the public from illegal operations that we do not want to be associated with; however, the proposed rule changes seem a bit strict. With a money back guarantee prospects should not have to wait 7 days to register, they can get their money back. Ligitimate companies already do this. Giving a list of references is good business practice but what about the person who is just starting, they don't have any yet? Just like in real estate the new agent does not have a list of past clients.And requiring us to disclose all of the law suits does not accuately portray MY business, that is what the Better Business Bureau provides for legitimate companies. Illegal/dishonest companies will ignore these rules anyway. Income claims should require simple illustrations and calculations AND statements regarding the prospects performance regarding income. Many times it is the new recruit that does not make any effort to perform then blames the company for failure. We see this alot in real estate as well as in Quixtar. And substantiating income claims is good business practice but should not be required. Again, this type of rule hurts the NEW business owner. Use real estate as an example... what if every agent had to give references and numbers on their last transactions? Sounds good if you have been in business for a long time because it monopolizes the industry to those who have been in business a long time. It limits the number of new agents thus creating a monopoly. While some of these rules seem to protect the public, the dishonest companies will just ignore them and in the end, the only people effected are those that are hurt by the restriction of the rules. These rules hold others back from having the opportunity to enter the industry becasue once they are involved they too will be required to go by these rules which will make it nearly impossible to succeed. Suggestion: Require a money back guarantee with no questions asked and the ligitimate companies will continue to do good business and the dishonest companies will quickly be exposed. Require simple calcualtions and examples that are easy for the public to understand regarding income potential. Don't hold people back from a chance to be in business for themselves. It is much like the dream to own a home. We should make it easy for Americans to be in business just like we make it easy for people to buy a home. We even government assistance for buying a home.Lets assist people in business ownership and elimate the dishonest companies through easily enforced rules like a money back guarantee.