| Comment Number: | 522418-05950 |
| Received: | 7/4/2006 3:54:05 PM |
| Organization: | |
| Commenter: | Ernest Gargas |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I can understand you concern regarding shady businesses being offered to people. I personally ran across a few of them; however my association with Quixtar and INA proves we are fully honorable and honest. Therefore, I pose the following changes to your ruling. Eliminate the requirement to provide 10 references. Eliminate the requirement to disclose past litigation. If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. This last solution of yours along with the others would greatly harm building my business and be an invasion of my financial pricvacy. It is bad enought that people do not return phone calls, keep appointments, loose or destroy my marketing materail. Now you want to give them 7 days to think things over! That would mean i would have to spend more time chasing them down to find out where they stand and maybe get my material back. Your ruling as it now stands would negatively impact my business, add to my overhead, cost me more time, and increase my losses. All of these costs would come right out of my pocket. As an Independent Business Owner, I believe the proposed changes would make his a win-win for everyone concerned.