Comment Number: 522418-07944
Received: 7/12/2006 1:35:59 AM
Organization:
Commenter: Randy Martin
State: TX
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

My wife and I joined World Wide Dreambuilders 12 years ago. We have used the business primarily for savings on personal use, small amounts of retail profits, and for the personal growth and development that WWDB offers. We have not focused much energy on sponsoring and building a large organization, although we have sponsored a few people who have also not put in much of a business effort. I like the general idea of helping prospects evaluate business opportunities, and helping them sort out the real ones from the scams. I feel there can be some real value in setting up some ways for them to do this research without them having to do it all from scratch. My main concern is that some of the proposed rule changes will adversely affect the honest business builders who will abide by them, while having no impact on the shady characters who choose to ignore them. What will be the consequences to those who ignore the new rules, and how will they be enforced? As I reviewed the proposed rule changes, I was at a loss to understand what the objectives were behind some of these new rules. The requirement of having to report all litigation for the past 10 years (regardless of its merit) seems way out of proportion here. How is a prospect supposed to evaluate that mountain of chaff and make an intelligent decision? Will this be a requirement for all job applicants as they interview at a given company as well? Is this a requirement when I go to buy a car at a dealership? Surely there are already adequate ways for prospects to investigate existing sources of information rather than me having to compile such a huge list of marginally relevant unfiltered stuff. What if we just point the prospect towards the FTC, BBB, and a couple other clearinghouses of public information, and let them do their own research from there? That way they can find both positive and negative information more relevant to their decision, rather than a laundry list of lawsuits they probably won’t understand anyway. The requirement of giving out such personal information as name, address and phone numbers of 10 other business associates in the area is a gross invasion of privacy unparalleled in any other industry I know of….I don’t even have that kind of information for the people on my day job. There are ample opportunities for prospects to meet each other at meetings, if it’s important to them, but I have not seen most propects wanting such personal details about others in the organization, once they’ve met them at a meeting and gotten a chance to know them in person. Some prospects want to meet lots of others to get comfortable, other prospects don’t have to weigh all that many factors to put up the minimal registration fee….Personally, we registered and THEN went to some meetings to “check it out” from the inside, figuring we’d get more information that way than we would from the outside….How much investigation is required for such a small investment? I sure didn’t research the suit store this much before I bought my business suit. How much information do we get when we buy a used car? Again, if this is a requirement, the honest people will be slowed down with compliance, while the shady characters will just create fake information or use the same safe list of each other’s names all the time, not really adding any value to the prospect’s decision anyway. Once again, I think this general idea can improve prospects’ chances of not getting ripped off by scams, but we need to be careful to get them useful information without bogging down the legitimate business owner at the same time. I have great confidence in the Quixtar IBO board to recognize where to draw this line for maximum effectiveness and minimum harm, so please continue to work closely with them as these rule changes are negotiated. Thanks for your attention and for your efforts in this important project. Randy Martin Austin Texas