|Received:||7/6/2006 7:42:10 PM|
|Organization:||Broughman Ventures International|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Affiliation of our business with QUIXTAR as the powering website has been an exciting alternative to shopping forays in traffic in this area. We have been involved in our business for over 6 years and thoroughly enjoy all aspects of helpng others achieve success through the business and association with other positive and achievement oriented individuals. The travel and function or education sessions have meant a great deal to us in moving forward in all aspects of our lives, financially and spiritually. We have developed a better family life and healthier life style, all contributed to positively by our affiliation with QUIXTAR and other Independent Business Owners. Affiliation of my business with QUIXTAR has provided me with extra income and time and money savings by shopping online for quality products. My wife has retired thanks to the income and I look forward to retiring with cash flow and dignity. The proposed rules, to the extent that they will not impede the opportunity for other people, are not entirely well-conceived. Specifically the seven day waiting period and furnishing of references are not provisions which would be easily incorporated into our business activities. The registration process itself involved in our affiliation with QUIXTAR sets forth approximately $135.00 to start, which amount includes products for about two thirds of same. The full price is fully refundable for six months and I have had no person who registered express any displeasure or sense of pressure for them to register. I always have told new prospects or registrants who are becoming Independent Business Owners that this business opprtunity is exactly that, an opportunity for creating a lasting business through the duplication process of other people and their access to online e-commerce and shopping. An opportunity requires effort for success at any endeavor. Any people who CHOOSE to affilate and register as Independent Business Owners are aware, because we candidly and forthrightly inform them so, that a simple process of duplication requires effort and old-fashioned work. In that regard, the proposd provisions for disclosing lawsuits and arbitration settlements have no relevance anymore than lawsuits or proceedings against major bricks and sticks retailers like Walmart or Target when people make a decision to shop at such locations. In short, I am opposed to a REQUIREMENT that such disclosures be made with particularity, since the ascertaining and collation and reporting of such adds unrealistic burdens to a process of education of Independent Business Owners. Likewise, the 7-day waiting proposal is an unrealistic restriction upon free trade and commerce by direct sellers. No person registers for business out of initial exposure or pressured tactics or coercion. Many registrants do so only after considered evaluation and question and answer process with appropriate written and oral materials to further answer questions and provide accurate and current information. The disclosure of personal financial records in undesirable. The record of achievement and financial success is, after all, a matter of individual desire and preference. To require disclosure inhibits the natural progression of development of what we call a "dream" or a vision of business that that particular person or couple can follow. Not every person is limited or motivated by the record earnings of another person. The long and short is that the propsed rule(s) has a good intent but should not be enforced across the board. Disclosure should not be mandatory, of financial records or of lawsuit or other matters of arbitration or unsubstantiated accusation of wrong-doing. Comparison methods are only as accurate as the information provided. Income is developed through duplication and education. The FTC proposals are onerous and burdensome to those people who honestly present an alternative to ordinary every-day commerce.