|Received:||7/14/2006 8:28:23 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To Whom it May Concern: I am distressed over some of your proposed regulations. In my experience as a business owner, I have benefited from having full disclosure of essential information as I had need of it. My personal mentors, by guiding me step by step on a need-to-know basis allowed me to learn and grow in my business ownership at a pace consistent with my ability and willingness to work. In no case was fraud practiced, and I was always made aware of the need for hard work, and the opportunity to withdraw, and recoup my expenses, should I so desire, within a reasonable time frame. I had ample opportunity to meet other business owners within the Quixter and Britt Worldwide systems, and learn from their experiences both before I registered, and since. I was excited about the opportunity from the beginning. But, if I had been forbidden from proceeding immediately, my initial excitement would have cooled and I very likely would have changed my mind. If I had been required to read documents on every disappointed person or family who felt like suing someone--with or without merit to their lawsuit--I know I would not be where I am today. ( I know of no business, however meritorious, that lacks detractors.) And, where am I today? I'm a better husband, father, neighbor, employee--a better man--thanks to the BWW education system and the Quixtar opportunity. (My daughter was 8 when I registered with this program. By age 12, she was begging me "daddy, please don't ever quit this business." At that time, we had not recouped a single dime of invested monies; she was just glad to finally have the daddy she had always been needing.) As regards the income claims, the basic format for providing explanations about the Quixtar opportunity as it exists today gives examples which are averages, provided that the business owner follows the instruction provided by the system. At the time of registering, full written disclosures of average incomes by all business owners in North America are given, whether they follow that instruction or not (substantially lower figures). It seems to me that requiring me to provide personal income disclosures, which may be far above average; and the next business owner to provide personal disclosures which may be far below; would violate your intent to combat fraud. Instead, it would create confusion, as these figures would, by the very nature of averages, appear to obfuscate reality. I hope my personal experiences and insights can help guide your decision making. I recommend using the Quixtar and BWW approaches, which require the highest standards of honesty and integrity, be closely examined. They would make excellent standards against which to measure the propriety of other direct selling business opportunities. Fraud, witholding essential information, and dishonest or misleading practices hurt all honest businesses. In my personal experience, such practices are vigorously striven against by the Quixtar and BWW leadership. Please allow them the liberty to continue to do so, at the same time they are allowed to guide and mentor those of us Independant Business Owners who are interested in and commited to success, by all measures, in our own futures.