|Received:||6/30/2006 7:56:24 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am greatly concerned about the burden the proposed business opportunity rule would have on direct selling companies and their independent distributors. I have been a Quixtar/Amway Independent Distributor for 10 years now and I know how honest this company is and that they expect great accountability from their independent distributors. While I don’t think this new rule is necessary for companies like Quixtar I do realize that because of some other companies a rule may be necessary. With that being said, there are some proposals in the rule that I find troublesome. I don’t believe that there should be a seven day waiting period before a person can register, especially with a company like Quixtar where the registration fee is minimal and refundable if for any reason the new distributor is not happy with the business. Any adult should not be restricted in their decision making process, if they want to register they should not have to wait and if they want to wait they are also welcome to do that. Distributors should not be burdened with providing extensive financial records. Our business plan is straight forward and people clearly know how much money they will make and they don’t have to invest in any inventory. Independent business owners should not have to provide a list of ten references as that could result in their prospect signing up with one of the references instead of the person providing the references. If new prospects are constantly calling these references it will be extremely burdensome on everyone. Everyone would be spending all of their time on the phone with these prospects. Keep in mind that many distributors are just doing this in their spare time trying to make a little extra money between full time jobs and caring for children. We are trying to keep the business simple for everyone but overly burdensome restrictions will end up pushing many people out of the business because they won’t be able to keep up with all of the extra work. I also think that requiring direct selling companies to list past litigation is extremely absurd. Many companies have litigation against them and often for frivolous reasons. Other types of companies are not required to disclose this information to every potential customer or employee so the direct selling companies should not have that additional burden. Anyone can go the Better Business Bureau’s website and get a summary of any litigation against any company and if the litigation was resolved in a satisfactory way. Because of that, this part of the rule should not even be necessary. Honestly I believe that because you can check out any company in the BBB’s website that negates the need for most items in this rule, if not the entire rule. If a company doesn’t register with the BBB then that should be a prospects cue to steer clear of that company. I do feel that a it would be a good thing for you to require companies to offer a reasonable refund policy as Quixtar does. Thank you for your time and consideration.