|Received:||7/15/2006 11:27:35 AM|
|Organization:||Quixtar - Affiliate IBO|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Can we really legislate people's intelligence? Can we legislate illegal/criminal intent from any business? Are we going to require that traditional businesses also make the disclosures recommended in this proposal before offering employment to a prospect? The Quixtar (Amway) business has always been a model of integrity, legality and honor. The corporation "legislates" itself as witnessed a couple of years ago when it dismissed a number of high-earning IBOs for not complying with the business rules of conduct. This corporation and its predesessor have always existed for the opportunity of the average person with very little capital to start a business of his own with the only limitation being his own desire and effort. The beauty of this business is the simplicity of it. You make your everyday purchases from a group of manufacturers that share the profits with you and you show others how they can do the same. You receive discounted pricing and for bringing other purchasers to the source you receive a bonus. All of this is declared on your individual tax return. Everyone has three (3) business days to cancel a contract. Why should there be seven (7) days for home-based, networking businesses to enter into a contract? Having to acquire special financial information from our corporation will be time-consuming and costly--negating our premise of little capital needed and being able to start your business right away. Requiring that every prospect be given a list of references from the IBO who is contacting them would be impossible for a brand new IBO just starting out--he has no references! Requiring substantiation for income claims--our business preview is already regulated and approved by the FTC. And, again, the nature of our business is that you earn as much as you want depending on how hard you are willing to work for it. Having to disclose "average earnings" is therefore very misleading. Are we going to require traditional businesses to substantiate their claims of earnings for jobs such as secretaries, window washers, accountants, etc? Will we be able to view pay stubs of their employees? Regarding disclosure of legal claims, lawsuits, etc. The traditional company which employs me is involved in 2 discrimination lawsuits. All employees have been informed that discussion of these lawsuits could mean termination of employment. What is the point in disclosing that there are legal problems if we cannot in any way discuss them with a prospect? Again, it comes down to trying to legislate personal intelligence. It cannot be done. Most of the items in the proposal can and should be checked out by the prospect on his own through various organizations and departments that provide this kind of information--Better Busines Bureau, FTC, etc. While there is a need for some legal protection against unscrupulous businesses, do not legislate harm to those good, solid businesses that have been a boon to the economy for a half century. Thank you for your consideration.