|Received:||7/2/2006 9:01:15 PM|
|Organization:||Francis Business Group - Affiliated with Quixtar.com|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I do commend the FTC in its effort to ensure that all necessary information is provided to prospects for work-from-home opportunities in order for them to make an educated decision. However, from the perspective of a new IBO through the Quixtar, Inc. opportunity, and considering the transparency already provided, there are some concerns I have regarding sections of the proposal. Regarding the 7-day grace period requirement: - I believe this is unnecessary given that any prospect who decides to educate him or herself can do so at what pace they would like. A 7-day grace period creates conflicts in managing the prospecting process and could lead to weeks from the time of providing documentation to the actual sponsoring. This hinders the profitability not only of the current, but the prospective IBO as well. Regarding the requirement to provide IBOs with disclosure of past litigation. - Any legitimate business should honestly be part of a regulating body that acts as an independent party to assess and give an opinion regarding legitimate complaints and claims of fraud, etc. These bodies include the Better Business Bureau and the FTC, which both watch over Quixtar with a keen eye. The person assessing the opportunity should be capable of researching credible sources for signs of legitimate business. Requiring calculation and different disclosures for every income claim - Understandably, some people can be unsure of the certainty of making the income claimed through a business opportunity. However, give the framework of credibility provided through FTC and BBB sources, a simple disclosure should be enough to show how the system works for the prospect. There are clearly infinite possibilities for income claims given the different ambition levels of IBOs and prospects. I recommend requiring a basic establishment of legitimacy through third parties who act as governing bodies to ensure that various income claims work out as the entire income plan shows.