|Received:||6/29/2006 11:02:50 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am an Independent Business Owner that contracts with Quixtar. While I appreciate the FTC's interest in controlling and eliminating fraudulent businesses, I believe the proposed regulations would place undue burden on legitimate direct selling businesses such as mine. I have been an IBO with Quixtar for nearly two years and am pursuing a goal of becoming financially free in order to leave my day job. I believe I can achieve that goal within five years. At present, however, I am only pursuing that goal on a part-time basis, with limited time and financial investment on my part. The proposed 7 day wait period is an unnecessary rule for IBO's (independent business owners) like me. I practice giving propects literature and listening materials, then setting a time for a later date to follow up with them, allowing them time to consider this business. I do this voluntarily, as do all IBO's that I personally know. However, they may have already considered this business and may want to register immediately in order achieve specific financial goals. To make them wait another 7 days may place an undue and unnecessary burden on them, specifically when they may receive their registration costs back within the first 30 days if they are dissatisfied. Currently, these costs are not prohibitive and are approximately $150, including an optional product pack. To provide a list of 10 references violates the privacy of other IBO's, since by nature they are independent of me and each other. To give out such a list would be similar to giving out names of people who have recently received an inheritance. It serves no purpose other than to violate their privacy, and to give pause to a prospect who may not want their name given out. It may also cost me a prospect if that prospect contacts another IBO and that IBO is a more talented presenter of the business opportunity. To give out a list of all lawsuits would be cost prohibitive for me, as such a publication would be too inclusive and would give a false impression of the business opportunity. It would likely include pending litigations, dismissed cases and false or unmerited suits. The charge would become worse than the evidence, and would give an untrue impression. To give separate disclosures at every point of income claim would become pedantic and tedious. It is more practical to give a simply understood disclosure once during the presentation, and to state that it holds true for all claims made during the presentation. This would make more sense to the prospect and would give a truer picture of the business. Any other rule would make the business opportunity appear more difficult than it actually is. Finally, to provide personal financial data and details outside of specific needs pertaining to an investigation, is again a violation of privacy. It is similar to interviewing for a job and asking the company president to provide similar details about his or her personal finances. It is in bad taste and is unnecessary considering the financial disclosure made during the presentation. I hope the FTC carefully considers crafting a regulation that protects the American people, yet doesn't prohibitively restricts the activity of IBO's such as myself. The proposed regulation, as it stands, could cost me my business future and eliminate any chance of achieving my financial goals. I thank you for considering my comments and I thank you for looking out for the well-being of business owners and prospects.