|Received:||6/30/2006 9:40:55 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been associated with Quixtar and its predecessor for 18 years. While I've never utilized its full potential, I've never regretted my association and am greatful for several unexpected non-monetary benefits. I applaud the perceived intent of the FTC Proposed Rule because unscrupulous schemes show up frequently, and their fallout causes damage to the reputations of all direct marketing organizations including good ones like Quixtar. I believe that efforts to require standardized income disclosure and a reasonable cancellation policy are good. However, I find the disclosure of allegations to be far too onerous -- especially unproven allegations. You will find that most allegations are against individuals and not the company. In any association, there is a certain percentage that becomes upset or angry about almost anything and they become quite vocal. There are also a growing number of lawsuit predators who make charges just hoping to collect money. We do not require GM or Ford to disclose every legal allegation before selling a car, and besides some of the worst schemes that pop up would have none to disclose simply because they are new. This is a bad provision. Please do not force me disclose my personal financial records -- that is private. No privately owned business should be required to make their financial records public with the possible exception of proven criminal activity. The requirement for 10 references would be cumbersome and nearly impossible in my rural area. Defining an area will be very arbitrary as well. The seven-day waiting period might be good for selling weapons or for making large investments -- say, greater than $10,000 -- but not for the paltry cost of becoming a Quixtar IBO. Will you make everyone wait seven days before joining Sam's Club or before making a small Wal Mart purchase? Don't do that unless it is for a large investment. The existing 3-day right to cancel period is sufficient for that, at least here in Missouri. Again, I applaud the intent. Please be very careful not to damage good individual businesses as you attempt to root out and stop fraudulent ones. Thank you from a retired military general officer, retired airline pilot, an active farmer and business owner, and Quixtar IBO.