|Received:||6/29/2006 10:33:26 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Greetings, I applaud the efforts to clean up the direct-selling industry. There are many fly-by-night disreputable operations that we must compete with. Unfortunately, legitimate business opportunities get lumped in with the deceptive ones in many people's minds. We have been involved with this company (Alticor/Amway/Quixtar) since 1987. In two years we reached the Direct/Platinum level and have since helped a number of our downline attain that level and higher. Our income of a couple thousand dollars a month has allowed my wife to stay home to raise and home-school our children for the last 14 years. There are just a few concerns I have with the proposed rule. 1) I don't think that a waiting period is necessary for people to register. There is no such period for purchasing a home. A 72-hour cancellation/refund period would be appropriate, again in line with a home purchase. 2) Disclosing all lawsuits and complaints against Alticor (a multi-billion dollar international company) would be unwieldy, confusing and of no real value. Every large company at any given times has a myriad of legal issues, many ultimately proving baseless. People are certainly free to and encouraged to check with the Better Business Bureau and state Attorneys general, as well as doing other research if they are curious. I don't know of any other industry that has this type of disclosure requirement. 3) Providing references could create confusion and has the potential of giving prospect leads to other IBO's. We currently refer people to IBO's in our upline organizational line-of-sponsorship for references and further information. 4) Our earning disclosures are currently very closely monitored by WorldWide Group, they are uniform throughout the organization and are very conservative representations. 5) I don't believe that providing personal financial statements/records would be appropriate. These are confidential matters that go beyond the scope of just one's Quixtar business. I have never interviewed for a job position where I was provided with personal financial statements by other people in the organization holding the same position I am seeking. Hopefully rules will be drafted and implemented which provide useful, honest information for prospects without comprising the privacy of IBO's and the integrity of the business opportunity being offered. This should help weed out the unsrupulous charlatans in the industry and make it a more fair playing field for all, actually enhancing the ability of honest business owners to grow their businesses and offer legitimate opportunities to prospects. People must understand that our business is a business, there is a modest start-up cost of a couple hundred dollars, some overhead of a couple thousand dollars a year, and hard work and time investment required. But the potential for substantial income is real, documented and occurring in our business every day. We don't guarantee equality of outcome (no business or investment does or can), but do guarantee equality of opportunity. Thank you for helping us keep this an honest, legitimate industry.