|Received:||7/10/2006 8:46:02 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:You want to make sure that consumers have the information they need to make informed decisions about participation in potential business opportunities. I support this goal, however, the rule as drafted has raised a few concerns for me and my business powered by Quixtar: 1. Waiting seven days to register: This would reduce the efficiency of my business. Currently, my prospects are protected because they have a 180-day money-back guarantee on anything they buy, including their registration fee. Instead, require other companies to have an acceptable cancellation or refund policy. 2. Providing references: This practice violates the privacy of current IBOs. And this could also encourage prospects to be “stolen” by IBOs that are called as references. I recommend removing this stipulation. 3. Lawsuits and arbitration disclosures: This is very cumbersome. Most people don’t want to know all that information. And if they do, it can be provided upon request. I recommend removing this stipulation. 4. Income claim disclosures: I already disclose the average income of active IBOs and provide an information sheet about the basics of the compensation plan and how the business works (the document is called SA-4400). Require all companies to provide the same type of information to their prospects. 5. Providing personal financial documents: Why? Does my employer provide their entire balance sheet to me? No. Additionally, my success does not affect them. They have the opportunity to surpass my income, if they work harder than me. It could potentially bias them one way or the other, and it’s not necessary. I recommend removing this stipulation. In summary, I am an honest person operating a business that is approved by the FTC. My prospects are clearly informed that this is not a “get rich quick” plan, but rather an opportunity to work smarter and to make money. They have a 100% money-back guarantee for 180 days, and I provide them basic information to make an informed decision about our business. I realize that you have a difficult task of trying to regulate the direct marketing business sector. There are many dishonest companies trying to scam people, and I want them out of business as much as you do. However, it is not necessary to penalize the good businesses that offer people a chance for a better life when trying to weed out the liars and thieves. Thank you for your attention.