|Received:||7/16/2006 10:15:07 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear Sirs: My husband and I have been Quixtar IBOs for the last three years. We have had moderate success in building our business and are very happy with the mentoring team with which we are associated. Any questions which we have asked have been fully and honestly answered. We are taught that integrity of character is of the utmost and should be practiced all the time in our business. Regarding the recent proposed rule entitled "Trade Regulation Rule on Business Opportunities," I would like to give a few comments for your consideration. It is my understanding that this rule proposes that prospects must wait at least 7 days after receiving disclosures before they can register as business owners. This restriction seems reasonable on the surface but would put an undue time constraint on already strained personal calendars, both the prospect's and the business owner's. They should be free to schedule the registration process on their own time frame. It has been our experience that the prospecting and registration process usually takes at least three weeks. In respect to the proposals which require references with complete contact information to be given to prospects, this is a direct violation of standard privacy practices which are being implemented by banks, hospitals, and other institutions. There could be dangerous individuals who would use this info to harm the reputation or credit record of the persons whose names are on the refererence list. Regarding disclosures of income during the plan and also personal financial records, this varies according to an individuals sales and bonuses. Is also a violation of privacy. A standard uniform generic example could be provided in written form with a disclaimer about sales and profit level bonuses. While I understand the differences between independent business owners and a corporation, if an ibo is required to disclose lawsuits and accusations against their affiliate company, then any corporation which hires employees should also disclose the same kind of information to potential employees. I believe this could also violate attorney - client privileges if information were to be disclosed prematurely or erroneously. Thank you for your consideration of my comments. I hope you will use wisdom as you continue to make amendments to the proposed rule. Our country's history is rich in entrepreneurs. People who are willing to assume the risks of a business or enterprise. Most have used a traditional business model. The independent business owner's motivation is no different than a traditional business model owner's motivation. They both want to improve their families' lifestyle. Please continue to allow them to have the freedom to do so.