|Received:||7/15/2006 8:10:00 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I would like to offer the following comments concerning the FTC Proposed Rulemaking for Part IV, 16 CFR Part 437, “Business Opportunity Rule.” I have been an Independent Business Owner (IBO) for Quixtar (formerly Amway) for the last 12 years. Frankly, this business opportunity has given me tremendous hope and security for my future financial stability with minimal financial investment or risk. Never have I felt that I was not fully informed about the risks or potential rewards of this business opportunity. Two of the great benefits of the Quixtar opportunity are its simplicity and low start-up costs (less than $200.00). This is why I am distressed to hear about this proposed rulemaking that would add an undue burden for those involved in this simple, but wonderful business opportunity. I have no problem whatsoever with reasonable, simple disclosure of the risks and rewards of a business opportunity. But I am opposed to the following provisions of the proposed rulemaking: 1. A seven-day waiting period (Section 437.2). This would greatly hamper the efforts of many Quixtar IBOs in sponsoring new people, especially people you sponsor in distant meetings, or when newly sponsored people want to sponsor friends at the same time that they get involved. Personally, when I heard about the Quixtar opportunity I wanted to start immediately and sponsor others immediately. Better alternative: Quixtar offers a 100% refund and Satisfaction Guarantee. 2. The list of 10 references (Section 437.3). For a business opportunity like Quixtar, this is unduly burdensome and an invasion of privacy. Each Quixtar IBO is independent. It is up to them whether or not they want to broadcast their name, address and telephone number to others. It is not up to me as their sponsor. Better alternative: list of references for the company (e.g., membership in Better Business Bureau, Direct Sellers Association, Dun and Bradstreet, etc.). 3. Disclosing legal actions for the last ten years (Section 437.3). This is entirely too burdensome. There are all kinds of frivolous lawsuits filed in this country against perfectly legitimate businesses. You cannot expect small entrepreneurs to track and disclose this information. People wanting to start small independent businesses like a Quixtar IBO should not have to hire lawyers to ensure they properly represent their business. Better alternative: published and verifiable track record (e.g., Quixtar and its affiliated companies have been in business since 1934—72 years!—with $6.4 billion in sales, more than 600 patents, and more than 3,800 employees in North America) and membership in the Better Business Bureau and the Direct Sellers Association. 4. Disclosure of detailed financial records for earnings claims (Section 437.4). For a business opportunity like Quixtar, this is an invasion of privacy. Each IBO is independent. Better alternative: Quixtar already has a form (SA-4400) which discloses the Average Monthly Gross Income for active IBOs as $115.00. It also states that 66% of all IBOs were considered “active” and goes on to define terms. It describes exactly how money is earned in Quixtar and shows the bonus schedule.