|Received:||7/12/2006 9:49:45 AM|
|Organization:||Baluh Enterprises, Inc.|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear FTC, I applaud your efforts to protect the public from "pyramid schemes" and fraud. I have read your proposal on the Business Opportunity Rule. Although the proposal is very much needed in theory there are several points I would like to make. I feel there is no need for a "waiting period" for the Quixtar business as a person can anytime rescind their decision to participate, long after the proposed 7 day waiting period. Next, as an independent business owner, I am unaffiliated with 10 other business owners and therefore the success these 10 IBOs have no bearing on my business success or failure. The prospect is affilated with ME and not 10 others. If I was approached by an IBO for references to their prospect I would not want to give any information regarding the possibility of success to another business than mine. Next, I find it hard to research litigation of other IBOs and it would be a hardship to spend time trying to understand other's problems and spend my productive time talking about alleged fraud cases whether true or not. I recommend you eliminate this part. In my Quixtar-affiliated business I pointedly explain that the prospects income is totally dependent on their level of participation and not on how hard I worked or did not work to get my success. No need for this. We already have printed material, even on our written or computer sign-up applications stating what the "average active IBO" makes in our business model. Now, in closing, I do have a recommendation. Since there are these "pyramid schemes" out there I feel that the FTC needs to publish a list of "approved" business opportunities that have stood up to your scrutiny and met the FTCs guidelines for true business opportunities. Give me a document or a place on your website that lists, Avon, Amway, Shaklee, and others as reviewed by the FTC and have been found legitimate for the public to participate in if the rules and regulations are followed, that the FTC had established for each business opportunity. The FTC is a very important entity for the public's protection and you can serve as a benchmark for real and honest opportunities of the Quixtar kind. I know that Quixtar's IBOAI board and the U.S. Direct Selling Association work hard to comply, reform, evaluate and review true opportunities and would welcome the FTC's review. Please help us succeed without cumbersome rules and regulations to our business. Thank you for reviewing my comments.