| Comment Number: | 522418-07947 |
| Received: | 7/12/2006 2:00:26 AM |
| Organization: | Wachtel Enterprises |
| Commenter: | Scott Wachtel |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am commenting in repsonse to the proposed FTC rule for Business Opportunity Rule, R511993. My wife and I have been affiliated with Quixtar for several years and have benefited greatly from our affiliation. When we were introduced to Quixtar it was made very clear to us the success and failure rate of new business owner's (called IBO's), and that this was not a get rich quick scheme. The business model requires an IBO to learn about the business through the use of tools which is similar to other businesses I have been affiliated with. I commend your efforts to clean up the industry and feel your rule does have significant value. However, several issues would be quite difficult to meet for a new IBO. Income claims would be based on information provided by someone else because a new IBO has just started their business. A seven day holding period is somewhat adverse to building a business. I would recommend a less restrictive waiting period but mandate a money-back policy. Our current policy requires an prospective IBO to research the program thoroughly before making their decision, no matter how long it takes. I have had one new IBO take a year and a half to make a decision. Requiring an IBO to provide references does not really protect the consumer. In all fairness to this concept, an IBO will most likely give only positive references. I respect your direction in improving the industry via improving rules and regulations. I have seen numerous get rich quick schemes that just do not work. Creating a fair and equitable playing field will increase success but can not prevent failure. Thank you for considering my comments. Scott and Karen Wachtel