| Comment Number: | 522418-09597 |
| Received: | 7/14/2006 7:41:57 PM |
| Organization: | Mammoth Enterprises |
| Commenter: | Paul Buckley |
| State: | MT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Thank you for providing an opertunity to comment on the proposed rulemaking. The FTC objective to provide information so that prospects to the Quixtar and other Business Opertunities are well informed is commendable. However, some of the proposed rule changes, in my opinion, would be ineffective at best and in some cases would also add very burdensome requirements to legitiment opertunities. I have been a Quixtar IBO for 7 years and although my business is only marginally profitable, that has been due to the limited time I have invested in building my business. The education system is very good and I have learnt alot during this time and have met many exceptional people. With that background to my business here are some more detailed comments on specific points in the proposed rulemaking. 1. The requirement to wait 7 days before registering an IBO would result in a stipulation that could be combersome and in the end be ineffective. For example this would require an extra trip to see an out of town prospect and the additional cost of that travel. It is better to leave this detail to the discression of the IBO and the new prospect. Some people are ready to and want to register right away others will ask to look over the opertunity before they register. This works well and as such the 7 day requirement is not needed. 2. The proposed requirement to provide 10 references would just simply not work. First of all a new IBO would not have a list of 10 references. I would not want to provide my name on a list that I wasn't sure were it would be distributed. In my opinion unsrupulous business would just make up a list of ten names and hand it out. In my experience and business newly registered IBO's are incouraged to attend montly meetings where they will meet other IBO's and can make up their own minds based on who they meet. They do not have to be registered to attend this meeting. 3. The litigation list would be very burdensome. All businesses have some law suits against them and so this would unfairly target my business compared with other business types. The indication that even alleged complaints would have to be listed would only encourage the people that develop negitive BLOG sites on the internet... would they all have to be listed? Not really very practicle or useful in my opinion. 4. The disclosure of specific earnings would not be useful since earnings depend on the structure of the network in a particular IBO's business. I provide my IBO's with examples of different business structures as a training tool to help them develop a profitable business. This works well and provides the new IBO with better quality and more useful information than providing specific examples. 5. Providing specific examples of my or any other IBO's income is an infringement on the privacy of that IBO. In addition it does not provide the new IBO with any really relevant information as there business will develop differentally than any example provided. It is better to use averages for all active IBO's or some similar statistic. Again thank you for the opertunity to provide comments on this rulemaking. Yours truly Paul Buckley