| Comment Number: | 522418-07464 |
| Received: | 7/10/2006 10:11:22 PM |
| Organization: | Quixtar |
| Commenter: | David McRae |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
16 CFR Part 437 Business Opportunity Rule; Proposed Rulemaking. Members of the Commission and others: As an independant business owner (since 1999), empowered by Quixtar, I am troubled by the overall tone of this rule proposal. It seems to present most small business in our industry as "individuals who go from one business opportunity to the next, violating Laws, committing frauds..." (as professed in your publishing). When there are many of us who have honest businesses, values and practices. Please do not victomise us with costly and combersum rules in an alledged attempt to combat criminals (who will not follow rule). Rules governing Business opportunitys with $500 or less in initial investment seems to be a good break point, these are small businesses investments, and small financila risks for honest business owners. some of your provisions would have big costs for compliance, both personal and financial. For opportunities like Quixtar, that offer a refund, the sopnsoring business owner and quixtar would bare all the costs for these rules, the new business owner would have none. (a condition that must be addressed) The seven day waiting period (bad idea and costly) first as a citizen for the Government to tell me I can't make a decision of my own, when I chose, is just wrong. As a business owner it will either limit my business area, or cost me thousands. {say I fly to Florida over a weekend to meet with a person who may, or may not want to start business (as I have). costing me more than $1,000. Your rule would require I come back in 7 days spending $1,000 more to do the initial work I would have done on the first trip. That could be tens of thousands of dollars every year this one rule will cost me} THIS IS A BAD AND COSTLY RULE PLEASE REMOVE IT. The requirement for providing 10 names, or worse yet a massive databaes of all business owners, Is also a costly and bad idea. Loss of prospects and the massive cost of that aside for now. Many small businesses are run from homes, unlike franchises and brick and morter businesses with protective store fronts. would you want your hope address and phone number published in a list of Government employees? There are criminals and less than honorable people out there. Privacy provides some security for our famlies, while requiring a remote phone numbers of all businesses would only have a pricetag of $300,000,000 per year or more for the security of this one point for phone and another $20,000,000 for a mail address. Thant about $340.00 per business, per year. (to register/start a business empowered by Quixtar is less than $100) People can get a refund if they find they dont want to have there own business. Also the 10 names and addresses could be from new businesses started the prior week, people who have entry level information only. Criminals could easily misuse this process, and information. This industry is a learn as you go process, with minimal investment risk, please don't add massive costs to it. The requirement that personal financial information be provided is also a bad idea, and can create an unfair advantage, or disadvantage. Change this to AVERAGE INCOME FIGURES. First, how much any one person makes will not deside how much another can make, BUT a prospect may ASSUME it will. Say the person presenting the opportunity makes $200,000 a month, will the prospect assume he will make that much. The new business makeing 200 a month will be at a big disadvantage. Do you want every American to publish there income? I wouldn't. Personal privacy as well. Quarterly updating of business numbers would also be a costhy process for publishing and distribution. This could easily be $100 per year, per business, @ 3 million IBO's thats 300 million dollars per year for this one item. These are small businesses, providing opportunities to people with no formal business background, in most cases. Please don't overburden them with costs, or safety issues