| Comment Number: | 522418-09305 |
| Received: | 7/14/2006 10:53:21 AM |
| Organization: | Quixtar |
| Commenter: | Greg Duncan |
| State: | MT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife and I have been IBOs for 25 years with the Quixtar/Amway business. This is our primary business. Our thousands of downline IBOs have always been treated fairly. Entry into the business has always been inexpensive at less than $50. Introductory product packages of another $50-100 have typically been suggested with full money-back-guarantees of they are not satisfied. The financial compensation has always been exactly as was represented. Nobody in our group has ever been misled into thinking this is a get-rich-quick scheme. Like any legitimate business, it involves hard work with proportional rewards. The most rewarding compensation is the abundance of intimate friendships that have developed around a business that has always been consistent and stable. The experience is so positive that many family members get seriously involved across multiple generations. We welcome FTC rules that create fairness across the spectrum of similar businesses. It is important that all prospects are given accurate information from every business without unnecessarily hamstringing the operation of those businesses. The intent of the proposed FTC rules are excellent. However a few areas of the proposed rules seem to be drawn from other types of business that don't apply to our industry. Some of these areas would hamper the operation of the business with no real gain for consumers. We have five areas of concern: Concern 1 regards the 7-day waiting period for registration. Money back to unsatisfied prospects offers enough protection. Concern 2 regards the list of references. This infringes on privacy and sends prospects to competitors. Concern 3 regards the litigation list that would include all false accusations and give a distorted, unfair view of our business. Concern 4 regards different disclosures for every income claim. We already use simple, standard disclosures that serve the consumer well. Concern 5 regards the personal financial documents. Beyond standard disclosures required by the FTC and similar state agencies, substantiation should be possessed to keep the claims honest, but should not be required to be disclosed. Thank you for your efforts to make this fair for everyone. Greg Duncan