| Comment Number: | 522418-05349 |
| Received: | 6/30/2006 7:01:48 PM |
| Organization: | World Wide Dreambuilders - J & N Associates |
| Commenter: | James Calhoon |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Having been an Amway/Quixtar IBO for the last 20+ years I find many of the proposed rules to be a hinderance to continuing running my business. Through this business opportunity I have been able to create a steady income to support my wife & myself with virtually no other retirement income. We enjoy not only a decent lifestye but literally hundreds of friends we have met who help us stay active and young - I am 80 years old and due to this business and it's products am usually considered a 60 year old at most. I want the same for others. When we were approached and registered initially we were shown a "business overview" which made it quite clear this was not a get rich quick scheme and the amount of income we would make was solely up to our production. We exceeded our expectations. It was made clear to us that we could quit anytime we wanted, and that we could get a refund if not happy - as well as a refund on products were didn't like. We continue to this day to supply the same information to anyone we talk to and show this opportunity to. World Wide Dreambuilders has an approved Business Overview that shows exactly how our business works - in writing puts the average an IBO makes - and shows how they can make more. Quixtar is one of the only businesses to have an FTC approved income statement. We personally never push anyone to sign up immediately, we want them to be sure of their committment, but a 7 day waiting period would be unreasonable. There isn't even a waiting period for buying a house or a car which is a huge expense with no refund! this rule would make it incredibly difficult to build our business. The requirement for giving 10 references would also be a hardship as those starting out newly in the business wouldn't have those references as personal knowledge. We have a large business and could do that, but then those being signed up newly would have to take our word for it. We have meetings monthly where any guests are welcome to come and meet alot of different people and speak to them, so if they have any question to the quality of people in our organization they are free to meet them at no cost and no committment. As well, prior to signing up there is no certainty that they wouldn't sign up with someone else we referred them to when we did all the intital work. As to the requirment to give a list of all lawsuits, this is completely unwieldy - to keep up with the information, and what about the suits that are found in favor of our business? Anyone can file a lawsuit! As well just because a lawsuit is filed about Quixtar - it may not apply to how World Wide Dreambuilders suggest we run our business. We have never had a lawsuit against our business ( J & N Associates) in over 20 years. As for income disclosures, this is adequately covered in our Business Overview and how we show the opportunity - depending on how someone structures their organization there is plenty of information on the Quixtar site to show the bonuses available and how they are made. Giving personal finance information violates our right to privacy and would still not give an adequate picture of what a new IBO would make. While we welcome rules for increasing honesty in the business world, the specific rules I addressed above put an undue hardship on honest business and don't actually address deceptive ones. Having been in law enforcement for over 20 years prior to this business I know that people who are dishonest will find a way around the rules - and only the honest businesses will suffer. Please do not implement these proposed rules as stated. Sincerely James F. Calhoon