|Received:||7/1/2006 6:41:38 PM|
|Organization:||Mulvihill Marketing/ Quixtar|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I wish to express some concerns about the proposed rule. While I wholeheartedly support the aims of the rule in creating a level and fair playing field for all opportunities and would welcome anything that would reduce the scams out there, the people who would do that will ignore the rule anyways. I felt I had more than enough info to make a good decision and my prospects all do also. We stress that this is not going to make them rich overnight and they will have to work at it. The prospect only spends $125 at registration and 60 of that has a money back guarantee(for products used or not).The 7 day waiting period would not benefit the prospect and would lessen the value of it to them, because they would be anxious to show it to friends and relatives. I would not be happy to be on a contact list of IBO's that others would have to give out and I would not be comfortable with having to give a list of names, I would have some concern that the prospect might decide to register with someone else.I think that restriction in conjunction with income disclosure requirements would jeopardize new people's ability to succeed as a prospect might choose the bigger business to join with. I also have a problem with disclosing my income to anyone else, in principle. We are already quite open with prospects about the average monthly income and the approximate income levels to expect at any level of the business. The provision about litigation is way too broad, and in my opinion unfair. Is McDonald's required to provide a list of lawsuits against their company and all franchisees to prospective franchisees? Additionally, the requirement of all allegations is not fair, as anybody can allege anything whether it has merit or not. The benefits of this business model in terms of lifestyle and personal growth far outweigh the amount of effort and risk necessary to succeed in this business model. I think the goal of the proposed rule is very beneficial, but the rule as written would be devastating to legitimate businesses that can provide a better lifestyle and better quality of life to many people. It would be a shame to hurt legitimate businesses in the effort to control the type of businesses that would ignore the rule anyways. the net effect of the rule as written is that the only ones who would suffer would be opportunities which are legitimate and fair already. Thanks for your attention.