|Received:||7/9/2006 5:57:57 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been in the Quixtar business 8 years. It has been a great benefit to me in terms of personal growth and friendships that have grown out of it over time. At my first exposure to the business I received a document that spelled out the average income of an active Amway distributor, it also showed me how other levels of income could be achieved with the compensation plan included in the document. The investment was about $100, and there was a money back guarantee. I have renewed my membership 7 times, and have saved on the cost of products I would be buying anyway. I have some concerns about the proposed Business Opportunity Rule 16 CFR Part 437. 1. SEVEN DAY WAITING PERIOD - This seems like overkill for a sign up cost that is less than $100, especially since it is made on a 100% money back basis. (After all I am not required to wait 7 days before buying a pair of sneakers for my son which costs a lot more than $100.) I think it would be better to require ALL companies provide 100% refund in the first X number of days after signing up. 2. LIST TEN REFERENCES IN MY AREA - First, who would give a reference to a person negative about the business? Second - If I gave references who were not in my personal down-line organization I would be opening myself up to competitors who could sponsor the prospect away from me. Third - If I gave references in my personal down-line organization I am opening myself up to raiding by unscrupulous prospects. Fourth – References are forced to take time and energy away from building their own businesses to help build a competitor's business. 3. LIST ALL LEGAL ALLEGATIONS - this sounds good, but an "allegation" is not a proof of wrong-doing. It stands to reason that the older, larger, and more established businesses that have proven themselves over time to be legitimate are bound to have more allegations against them than the latest fly-by-night smoke-and-mirrors get-rich-quick scam you are seeking to protect the consumer from. It seems to me that the effect of this proposed rule is to penalize legitimate businesses, while illegitimate businesses will simply ignore the rule. 4. INCOME CLAIM SUBSTANTIATION - This sounds great, but because one person did well doesn't mean the same opportunity exists for everyone. Instead, I would like the FTC to set forth a clear, simple, and standardized income disclosure form that all direct sellers are required to present during the recruiting process. The document would need to be easy to understand, and as such enable a prospect to conduct side by side, like to like income comparisons of various direct selling opportunities.