|Received:||7/13/2006 2:28:46 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO about 3 1/2 years. While income is essential to existence, personal growth, education and community are very important in shaping one's future. As an IBO I am able to accomplish more than simple income and I express this to prospects. I encourage prospective partners to join me for an "in the kitchen" view of our company by previewing the meetings and materials. If unhappy following joinder, refunds are available, but only one time was it sought (but later he recanted his request and is now an active team member). While income is usually the desire of many, we stress that joinder is not in place of work. We have a system,but "you do the work." Annual averages for the typical achievement levels are mentioned, but always couched in the real caution that each IBO postures themselves differently and so their income will vary from the average. This was the advice I received and this is what I pass on to prospective teammembers, as disillusioned teammembers don't perform well. As to a waiting period, I would suggest the injection of one would be harmful to my business. I have found that quick movement and success early on helps to move anyone and to delay that process will reduce my growth potential and place new members at a distinct disadvantage. The delay would also disrupt the building process and would create uncertainty in the formation of "downline" business structure. This would probably lead to assertions of misrepresentation as to final placement in the team structure. The requirement for references would be potentially dangerous, as this would require me to refer my prospect to a competitor, hoping that my person would continue to remain loyal to me. If he chose to switch sponsors, would he then have to wait another 7 days? Would there be penalties for raiding on reference seeking? As to the listing of litigation re the "seller", I am not sure who this references, the parent corporation or everyone from the top down, whether or not they are known to me or even in my team? This seems very burdensome and vague, when most of the litigation information can be obtained on the webb with a simple search anyway. There are enough sites that contain negative information on any topic available to all inquirers to make this redundant. I take offense to financial disclosure requirements, as only public servants, not private industry is held to that requirement. I have multiple streams of income; would I need to disclose all to a prospect? What benefit is served by disclosure when the reward is dependant upon work and the movement of product? Our materials already contain earnings disclosures as to the income of the "average IBO." One should also be cognizant that any long term investment's value is not determined by the income level at the early stages of the project. Why should this model be subject to this, as it is a meaningless disclosure? It is my belief that save the waiting period and financial disclosure, I find our organization benefiting from open discussion of the work and effort needed to produce income. Meeting the people already involved seems to stimulate people, not repell them, so I find references being a silly delay and confusing. Who ever sends his prospects to a competitor? What rules would the reference need to abide by to ensure fair play? Aren't we looking at creating more troubles than might be resolved? While truthfulness and fair play are a benefit for long term relationships, how do we accomplish this by rules? I find the concept of legislating fairness and truthfulness a pathetic effort at protecting people from themselves. Why not simply encourage people to research the people they go into business with, not hamper the process?