|Received:||7/5/2006 11:00:23 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I will address each point I feel most significant in the proposal: 1. Having to wait 7 days prior to register after receiving disclosures would greatly hinder the very legitimate and appealing concept of being profitable from day one. I think the waiting period should be eliminated. 2. Having to give a referral list of 10 IBO's with personal info is absurd, since this could result in other IBO's sponsoring your prospect. It would also infringe greatly upon the privacy rights of any particular IBO's, since who is to say that they be the only 10 IBO's in a region from which a sponsor is working. This requirement to provide 10 references should be eliminated. 3. Requiring disclosure of past litigation is irrelevant since it will not solve the problem of illigitimate business practices by companies who by their character do not care. It would also only make allegations be put forth as grounds for decisions of prospects, and allegations are not necessarily truth. The requirement to disclose past litigation should be eliminated. 4. A different disclosure for every income claim is unreasonable. Every possible scenario of sponsorship or income variation would not change the fact that profitability is based always upon performance standards. A simple, standard, easily read disclosure (which incidentally has already been used effectively) would be the only reasonable solution, if a disclosure of any kind was mandatory. I do not even think any disclosure should be mandatory. 5. Requiring IBO's to substantiate income claims with personal financial documents to prospects should not be required, since this can impose psychological restrictions upon prospects when they may not feel they could achieve your level of success. What I am capable of doing by my free will has nothing to do with my prospects' level of success. Once again, the level playing field provided through Quixtar by default presents the same opportunity to anyone.