| Comment Number: | 522418-05192 |
| Received: | 6/29/2006 11:32:51 PM |
| Organization: | quixtar inc. |
| Commenter: | Rob Feinberg |
| State: | NJ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To whome it may concern, i recently became aware of some change you want to make to laws that regulate bussiness opportunities for every day people. I do very much agree youo got to have strick laws to protect the people of this country so now one gets taken advantage of. But i feel with the changes you want to make are not proper for all bussines. below is a list of issues i have. Problem 1: Prospects would have to wait 7 days after receiving disclosures before they could register. what i feel would be better is if they made it so they have to give a money back if not happy for the first 30 days. Problem 2: You would be required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other IBOs in the area – seven days before the prospect registers. My problem with this that it says any stranger in my area can be given my personal info and i can get phone calls from stranger at any time and can become harrasment. i personal dont want just any one to have my phone numbers or anything like that. also with in home bizz opts there usaly is a "line of sponsorship" in place already with people that have the best intrest in the people involved, if you have people that are outside that "line of sponsorship" it could cause people to loose money becasse you are counting on strangers to say something about your bizz. Problem 3: You would have to give every prospect a list of all lawsuits, arbitrations, or other legal claims for the past 10 years involving your opp. where the plaintiff alleged fraud, misrepresentation, or unfair trade practices – regardless of whether or not the accusation was true. My issue is that you will be force to show that a lawsuit happen but you cant tell the person that it wasnt a real suit. if this is the case then i fell when i guy a car or any other item that company has to tell me about every singel problem that product had or any law suit that product had but dont tell me how many were people just looking to prove something. I feel this shouldnt be part of it at all. now if you are deal with a company that works on poor values that arent going to give the proper info anyway. Problem 4: You would have to make a different disclosure for every income claim.This would include any examples you might use during an opportunity presentation to illustrate how the Plan works. Solution: If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." Problem 5: You would be required to provide prospects with personal financial documents to back up ("substantiate") any income claim. My problem with this is that i feel income is personal and that no one should know what i make other then me my family, acountant and anyone that has a intrest in helping me with my income. i feel anyone else is none of there business. Before you make any sort of changes please consider what i have said in this letter. sincerly, Rob Feinberg