| Comment Number: | 522418-10212 |
| Received: | 7/15/2006 10:55:07 PM |
| Organization: | Kuchenbecker Business Group |
| Commenter: | David Kuchenbecker |
| State: | WI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern, I'm writing in regards to the proposed law changes for direct sellers being considered by the FTC. I got involved with the Quixtar Corporation as an IBO approximately 5 years ago. I have not been the most active IBO, but have had success with their business model - and enjoy rewards from the business. I am all for giving prospects adquate information to make a decision. Many times, I have had prospects attend many meetings, listen to resources, meet others, etc many times before deciding to get affiliated with Quixtar. However, the rules about providing references, a 7 day waiting period, and financial documentation will not be helpful. What I've found is many prospects aren't that concerned about those things. If you overwhelm prospects up front, they lose track of why they were interested in the first place. Another problem I see with some of the proposals is a cost increase for my business. If a prospect is ready to go right away, why should I have to tell them to wait 7 days ... then maybe have to travel to meet them again, etc? I support a reasonable cancellation policy, which Quixtar has in place - but I do not support making all people just wait. One of the powers of our business is to make an opportunity available to anyone who would like it. The requirement to provide a reference list would be difficult if the prospect is in a new area where there aren't other business owners. The other issue is the business owners on the reference list will have to take time to potentially talk to ny prospects - as well as their own? The last part of the proposal I have an issue with is disclosing financial information. One of the most sensitive times in the business is when a new person is starting. Like all businesses, they don't have financial results the first days or months. The lifestyle of the people I'm involved in business with should speak enough to how much money is available. IBO's I'm affiliated with already show an example of how much money would be made using a theoretical example (the WSA-4400 form). From this, a propect can calculate any size of business they want. If they require help, I'm more than willing to assist them. Again, many prospects aren't interested in this type of detail. I hope you consider the proposed changes carefully. The parts of giving prospects all the information required up front is great - and I believe most long-term businesses have been doing this for a long time. Some of the other parts of the proposal though will harm our businesses more than help them. Hurting business is not what the FTC is around to do. Regards,