|Received:||7/11/2006 10:16:52 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I applaud your efforts to protect people from fraud and scams. Every prospect interviewed should have accurate and honest information to make a sound decision. However I feel that the proposed rule unfairly and unnecessarily restricts legitimate businesses. The requirement for a prospect to wait 7 days before registering would make it very challanging to manage and it will delay the possibility of new people getting started in their own business. Would you require a store front to wait 20+ days from opening day to the possibility of selling their first item? Providing references is an invasion of privacy for the individuals being referred. Normally my prospects will meet several IBO's prior to registering and have the opportunity to discuss business face to face. Presenting the total litigations list is an undue burdon on the IBO's. An individual investing in Microsoft or IBM is not provided a list of all possible litigation prior to buying a share. It should not be required for individual business owners either. To my knowledge all of that information is available either on the web, or through the better business bureau. If required, perhaps a simple web address could be provided to allow individuals to research for themselves. Specific earnings disclosures are another invasion of privace and potentially misleading. A better solution is to disclose what the average income is for a given performance level. Also full discussion should be made that this is not a "get rich quick" scheme and that time, work, and effort are required prior to success. Just like any other endeavor. The requirement for financial substantiation is inappropriate. If there is a compaint of fraud or deciept, documentation should be available. Thank you for your consideration of my opinions.