| Comment Number: | 522418-09313 |
| Received: | 7/14/2006 11:09:24 AM |
| Organization: | |
| Commenter: | Doug Maynard |
| State: | NH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-09313.pdf Download Adobe Reader |
Comments:
This is in response to the proposed FTC regulations relative to "Trade Regulation Rule on Business Opportunities." While there are some unscrupulous programs out in the marketplace there are many more successful and legitimate business opportunities. We have enough laws and regulation on the books already. Why don’t you enforce them? We have been IBO’s in the Quixtar /Amway business for over 15 years. We have found the program to be honest and the opportunity presented in a straight forward and factual manner. They take great efforts to assure that there are no unsubstantiated claims of success and/or income levels. In addition there are many benefits beyond the income available. These involve both personal and professional growth and improvement. When we began we were factually informed of what we could expect and what we should not expect, including the need to exert effort if we expected to reap any financial rewards. This was also taught at every step of the process. When we registered new IBO’s we taught the same philosophies. Typically, the cost to start a new business is less than $200.00. A true bargain, in every sense of the word. I currently have traditional businesses where my investment and risk far exceeds any costs or risk with the Quixtar business. I have also had traditional businesses which failed and our losses were enormous. There was also no one around to try to help us pick up the pieces and move forward, except our Quixtar ‘partners’. I see absolutely no value in a 7 day ‘cooling off period’ before being able to register. In our world of fast food offerings and 30 second commercials, which cure every malady of the known medical world, our attention span has become relatively short. In a 7 day cooling off period people will change their mind dozens of times on a wide variety of subjects. It simply serves no purpose but to potentially rob a prospect of the opportunity to better themselves with little at risk, except for their own efforts. In regards to the proposal that we provide references … I am on every ‘do not call list’ that exists (I believe) and would not appreciate a ruling that would require that my name be given to many people that I do not know. How would this apply to the current “do not call’ rules? Relative to the litigation list, you people would be well advised to try living with the rules you propose. This is one of the most ridiculous suggestions I have heard. How many lawyers will find new employment in satisfying this requirement? How about in just defining what and who is required to be disclosed. Exactly what are you trying to remedy with this suggestion? In reference to the financial information, Quixtar already has a process to ensure that financial claims are substantiated. It is called the SA4400 and it shows, in detail, income expectations and possibilities. As far my personal income is concerned this is my private information and nobody else’s business. How about you release your income? How much money do you make developing these silly regulations? You want to be involved in my business, through regulation, so don’t I have a right to see your income statement? Of course I don’t and neither does anybody else. Police the bad guys and leave the rest of us alone. Thanks Doug and Lynn Maynard