|Received:||7/3/2006 1:54:51 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Thank you for this opportunity to comment on the proposed Business Opportunity Rule referenced above. I am strongly in favor of such a rule which requires all independent home-based business owners to provide adequate information for a prospect to make an informed decision regarding their own involvement in the business. I must say that during my past 10 years of business affiliation with Amway, Quixtar and Alticor the companies have made every effort to be in compliance with all applicable laws governing their operations and have kept their Independent Business Owners fully informed of the required disclosures to be made to prospects. As an IBO with Quixtar I have generated an extra monthly income of about $500 which has clearly improved my family's lifestyle and kept us out of financial difficulties. This web-based company has also made our basic shopping needs very simple with direct delivery of the biggest majority of our consumer goods. Since we do recognize that no amount of rules can totally remove all risk from a business venture, making these rules reasonable and workable is a must in order for legitimate and ethical businesses to thrive in our competitive economy. The prospects I work with usually make their own waiting period in order to search out more information on the company and are always encouraged to do due diligence before signing up with the business. Requiring a 7 day wait would surely hinder some entrepreneurial individuals from starting up and bringing others on board when I am unaware of any precedent for this type of restriction. We already make a clear offer to fully refund the person's investment if he decides not to continue with his initial commitment. In addition, full disclosure of all litigation within a 10 year span would seem an impossibility for the average business owner who is building a network with other business owners. Again, I must ask -- is there a precedent here? For example, does a pharmaceutical sales representative have to make full disclosure of all litigation against his company or any drug produced by that company when promoting a product to a pharmacist or a medical practitioner? I am in favor of honest and factual disclosure of real income numbers being earned by business owners within the recent years. Through our Quixtar-approved literature and business presentation materials we have accurate average income numbers which are shared openly with prospects. We also make it clear that no income is gained without the purchase or sale of products from the company or its affiliated stores and I routinely make it known to prospects that work is required in order to build this or any successful business. I look forward to reviewing the next edited version of this ruling from the FTC.