|Received:||7/9/2006 11:28:43 PM|
|Organization:||Lederman & Associates (Quixtar)|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an active IBO along with my husband since 1989 and have been a qualified Platinum since 1992. When we were shown the business we were told that in order to make money it would require effort and hard work. We were also presented with a document (SA4400) approved by the FTC which described the compensation plan as well as average incomes at specific levels. We continue to do the same thing and teach it to all who join our organization. My experiences with Quixtar (formerly Amway) have been excellent. Everything is done with the highest of ethics and I am proud to be affiliated with such a fine corporation. Because of this opportunity I was able to be at home with my kids during the teenage years. As a family we all benefited not only from the financial rewards but also from the association with others who shared similar goals and values. My children are adults now and have joined with us in our business. That's the biggest testament of all to a great opportunity! I am aware of the FTC's concerns for keeping this industry honest and totally appreciate that. However, I do believe that some of the proposed rules would be detrimental to our business. A requirement to provide prospects with a list of references would do more harm than good. Most people do not want their phone numbers given out....it's an invasion of their privacy. As an IBO I would not want to be putting my prospects in touch with others who might try to sponsor them instead. Also, a newly sponsored IBO might not even know 10 others yet. When I got involved in the business the only person I knew was my sponsor. We met many others at the opportunity meetings we attended. In fact, at the end of the meeting those who reached a certain level came up front and spoke for a few minutes. We still do that today so everyone is given the ability to see others who are involved and speak with them without infringing on their privacy. The requirement to provide a list of lawsuits, allegations, etc is very disturbing. We live in a litigation crazy society and we would be spending valuable time answering questions that no one was even asking. Today it is very easy for anyone to find that information if they so desire. The major issue I see is that this ruling could open the door for unethical competitors to file lawsuits or make allegations knowing that we will have to disclose them. Physicians and surgeons literally take our lives in their hands every day and they are not required to supply this same kind of information. It seems to me that the risk involved in a business that costs $150 (including products) which is refundable doesn't need such extreme measures...it's like killing a fly with a sledgehammer. I would not want to have to provide prospects with personal financial documents to back up income claims...that's no one else's business. I have never made a specific income claim in all these years but have told people what my income has provided such as college educations for my kids. I also have told them exactly what I did to attain that. In fact I have always been taught that as IBOs we should not be divulging our specific incomes because it will be different for everyone based on how they structure their own businesses. In closing I do appreciate the work you are doing so that consumers will have the ability to make decisions based on proper information. At the same time I ask you to understand that some unnecessary restrictions will impede the growth of our current businesses which will ultimately prevent the very people you are trying to protect from experiencing a great opportunity. Thank you.