| Comment Number: | 522418-08621 |
| Received: | 7/13/2006 2:37:11 AM |
| Organization: | |
| Commenter: | Dale O'Neil |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear FTC, Thank you for an opportunity to give my input concerning the proposed rules affecting the Direct Selling industry. I am an Independent Business Owner (IBO) affiliated with Quixtar.com. Several of the provisions, I believe, could be detrimental to a legitimate business such as Quixtar and/or are already addressed in our Business Rules and our Code of Ethics. 1. Quixtar backs its registrations with a similar comprehensive money-back guarantee to that which its products enjoy. A seven-day waiting period would not only be less of a security than a money-back guarantee, but our internet-based business is built for speed, in that an enthusiastic new IBO can share this opportunity with his or her contacts anywhere in the United States the same day he or she registers. 2. Providing a list of lawsuits will not only invite false accusations, as the outcome of the case is irrelevant, but disreputable companies will likely ignore such a rule anyway. 3. A requirement of providing ten references places a logistical burden on a new IBO who has no such contacts. More importantly, personal privacy will be jeopardized. Also, in spite of the original persistent, conscientious IBO doing the work and overcoming his fears, reaching out to this new prospect, the prospect now may choose to shop around for a different sponsor. 4. Quixtar IBO's already provide FTC approved disclosures (The Independent Business Ownership Plan) concerning average income for active IBO's, separate income disclosures are not needed. 5. Personal income disclosures are no one else's business outside of official agencies such as the IRS. In these days of identity theft, such requirements are difficult to justify. Thank you for your efforts to keep our industry streamlined, legitimate and wholesome! Respectfully, Dale O'Neil