| Comment Number: | 522418-05062 |
| Received: | 6/29/2006 12:55:25 PM |
| Organization: | Cockfield & Associates, LLC |
| Commenter: | Gary Cockfield |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Hi, I have been an IBO now for over 10 years and love my Quixtar business. We enjoy the atmosphere and the friendships that have come being involved in this business. Knowing that our business is and always has been governed by the FTC is a confort to me and to my prospects. It is good that the FTC is working to eliminate the bad and illegitimate business opportunities. I was well informed before we registered and make every effort that prospects are also. I also knew that this wasn't a get rich quick opportunity and it required work on my part. I knew that all the products came with a money back guarantee. Now in the ten years that I have been in business I have never registered a prospect on the same day they looked at this business opportunity. I see no need at all for a seven day waiting period for a legitimate business or an informed prospect. There is no benefit to either side and could increase business cost greatly when traveling. I want prospects that are informed and want to be active and willing members of my team. As for references, if this opportunity was a bank and the prospect was looking for a loan and I had to send them to my competition. How could I stay in business and how would this stop the bad businesses? What about privacy having to give out names and numbers? We freely talk about and introduce prospects to other members of our team. Disclosure document involving litigation, how would the average person know where and how to get them and what to look for? How would this help the prospect and how would it stop the bad businesses? This would hurt the legitimate businesses. The disclosures and explanations of potential income is already governed for our business by the FTC. There is no benefit to anyone with additional detail, again how does this stop bad businesses? Besides the illegitimate business opportunities don't obey the rules anyways. The requirement for financial substantiation of personal income to prospects is totally out of line. Any income is the direct result of ones own efferts and there are no income guarantees. This is inappropriate information to share in any industry and grounds for immediate termination in most businesses. This again would harm the good businesses and have no effect on the bad. Yours Truly, Gary A. Cockfield