| Comment Number: | 522418-07453 |
| Received: | 7/10/2006 9:23:22 PM |
| Organization: | Quixtar Affiliated Independent Business |
| Commenter: | Justin Yadlosky |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Our families have been Quixtar Affiliated Independent Business Owners for almost 10 years now and cannot justly put into words the joys, business experiences and personal growth that we have all gained. I commend the FTC for pursuing appropriate legislation to keep tabs on business practices and enable free and fair opportunities. We all have seen the ENRON story! However, in its current form, the "draft" proposal as written takes these regulations to the other extreme (kind of like the Medicare reform initial draft). As a fellow ex-compliance manager with CFR experience, I would suggest a few changes or clarifications to protect the opportunity seekers without "hand-cuffing" the industry. 1. Personal Financials - Do all other industries require this? I have never had my Doctor, Lawyer, Mechanic, Grocer, etc. ever volunteer their personal financial situation. Perhaps more focus should go to the corporate arena (i.e. ENRON and the like) before beating up on all the little guys. 2. List of All Lawsuits for past 10 years - Shouldn't future business owners have to take some responsibility to research what they are about to invest in (maybe use GOOGLE)? If all businesses had this clause we would probably shut down the entire economic system, while keeping the lawyers busy...then again, they aren't regulated/required to share their financials wit us...Joe Public. 3. Reference Lists - Perhaps this as an option or "were you offered to contact other business owners" may work, but as a requirement? Doesn't that basically infringe on peoples right to privacy? 4. Seven Day Waiting Period - If you can get 100% of your money back (therefore being RISK FREE) what is there a need for a waiting period? (We don't even have to wait that long to buy a firearm). Agreed, if the business opportunity does not offer a 100% money back guarantee, then some regulations do need to protect the consumer/future business owner. In summary, please proceed to make some changes to the current "first draft" to ensure our freedoms and liberties afforded to us via the Constitution are not infringed upon. And many thanks to the people working to ensure adequate consumer protection for all of us in our great nation, The United States of America. Thank you in advance for your time. Justin Yadlosky