| Comment Number: | 522418-10439 |
| Received: | 7/16/2006 2:00:18 PM |
| Organization: | Walsh&Sons |
| Commenter: | Patrick Walsh |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sirs We have been involved in the direct selling business from 1991-1999 with our Amway business. In Sept. of 1999 we converted to an online business "powered by Quixtar". We applaud FTC's efforts to ensure new prospective business owners a viable opportunity and prevent scams and get rich quick schemes. - We have never earned income from recruiting fees. -We don't promote or encourage front end loading. -There is no risk. ($42.00 registration /guaranteed money back policy) -We provide our new prospects with a current prospectus. -Each sponsor pledges support & guidance and an introduction to successful builders in a single line of sponsorship. We appreciate your concern to keep new prospects from being duped, but feel some of your new proposals are harmful to our business. -The 7 day wait would remove the advantage of online, and seems unnecessary since there is a money back guarantee. -The 10 references rule would encourage damaging crosslineing, and also intruduce prosective new business owner to other possible sponsors also capable of registering this new prospect outside of our single line of sponsorship. -Disclosure of past litigation doesn't distinguish False from true allegations! We encourage the FTC to establish a list of approved direct selling businesses, which would allow the prospective new business owner to have confidence ,that the business under question is legitamate. Each new business would then be required to submit a prospectus (example of average monthly earnings for business owners) to the FTC to gain access to your approval list. Thank You for your consideration and time! Patrick J. Walsh