| Comment Number: | 522418-05666 |
| Received: | 7/2/2006 10:52:12 PM |
| Organization: | |
| Commenter: | Mike Stern |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been an Amway/Quixtar distributor since 1981. Amway pushes the IBO's to sell products and use company sells borchures. The diamond level and above IBO's push their seminars, brochures, sells material, etc and not products. I do think your idea of regulating "door to door" and "direct" sales opportunies is a great idea. Your proposals are a bit over the top. I do think that there needs to be a cooling off periond. Seven days before signing up is a bit too much. Probably 3 to 5 days is enough with a 30 day money back guarantee. I do think there needs to be a strong warning about IBO's selling their own business material and seminars that are separate and not a part of AMWAY/Quixtar. This does create confusion. fraud, peer pressure to purchase non=Amway/Quixtar promotion and sales material. Having full disclousre of money earned is a good idea. Just need to be carefull it does not become a burden on the IBO's who are trying to earn a living. The same for the full disclosure of all ligagation. Maybe an on-line link would be enough for that problem. I am sure Amway'Quixtar like any company has its share of lawsuits filed against them. No sense making the IBP's responsible for providing all this invormation when an on -line link would work. I commend the FTC for trying to control and requlate companies who commit fraud. There are IBP's within Amway/Quixtar who are guilty. I think the company does a decent job of removing the quilty IBO's. I would stronly recommend the FTC sit down with the Direct Selling Association that Amway belongs to and have a heart to heart discussion. I do believe you will find that Amway and other long time leginimate direct selling companies will work with you to develope a fair set of regulations to benifit and protect the American public from "crooks" in the industry.