|Received:||7/13/2006 12:18:17 AM|
|Organization:||C & L Consultants|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have owned other businesses than my Quixtar direct selling business. When I sold my other businesses; the buyers did their due diligence. If they had a question; I supplied the answers or documents. They could back out of the deal at anytime. Quixtar already has in place a full money back guarantee. A rule requiring a money back guarantee for all direct sellers allowing the injured parties to start at their sponsor then work back up their group could address this concern. As more people could be liable for indiscretions; this would police itself. Another challenge; the income disclosures, could be handled in one rule that would force the parent company to publish their own averages independently audited. The provision that each prospect be given a list of lawsuits or arbitration for the past 10 years; I am afraid that this will overwhelm an all ready busy court system with legal actions between the different direct sellers just to make the other look bad. I could give a list of 10 references that would always be favorable. My opinion is that overall the direct sellers are honorable and have integrity. To unduly place restrictions; as the anti franchising laws in the 1950s would in effect have a negative impact to our economy. As in the case of my quixtar business; to slow progress of internet commerce will adversly affect the U.S. economy and give unfavorable advantages to off shore companies.