|Received:||7/17/2006 12:01:39 AM|
|Organization:||Solveware Consulting Inc.|
|Commenter:||J Tyler Parcher|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Regarding proposed rule making called the Business Opportunity Rule, the following recommended provisions would impose a crushing burden on our operation and would effectively shut it down. I asked that the proposed provisions described below be removed from the regulation document. 1. The provision requiring us to supply list of 10 references from other business owners in the area would hinder our ability to open our business opportunity to new "areas" where there are not yet 10 businesses. We want to bring our opportunity to areas that are under served. This provison would distort that free market concept. Business would be encouraged to start up only where there already sufficient coverage thereby stalling our growth. 2. The proivision requiring a seven day waiting period is unreasonable when you consider also that the IBO registration fee is just $45. Any other fees are elective for the prospect. Many of our customers sign up as IBO's ONLY to get a buyers discount afforded to them for paying the up-front IBO registration fee. We present that concept as a possbile option. We belong to a "SAM's club" down the street but we did't have to wait seven days after signing up to spend our money there. How is the Quixtar opportunity more of a commitment than that? I think its just $10 more to register foir Quixtar than it is to join a Sam's Club. United Buyers club charges a whole lot more money up front for their discount plan. Now there is an example of a commitment. We don't want to lose that vital segment of our business (the people who just register to get the discount). They represent a substantial portion of our trade. A seven day wait is a crippling and unreasonable requirement for $45 registration fee. We already do a 48 to 72 hour wait already as part of our presentation process for persons who are looking to get more than just a "club discount" for their registration fee. There is no need for this kind of regulation. 3. Building a community of buyers and distributors depends on duplication of our business promotion methods. We serve persons in all walks of life, many of whom never have worked in promotions before, (including myself). If doing promotion for a service that trades in things like groceries (as we do) gets to be as complicated as buying a house people aren't going to do it and I won't ask them to. When you start talking about "disclosure" at this level its starting to sound like the real estate trade. The Quixtar opportunity doesn't trade in big money transactions like that. Its just about people saving money through bulk buying of things like grocery items or small appliances like you might find at Wal Mart. No, I'm not about to ask other people to build a buying community by thelling them they have to present complicated disclosures to their prospects or by exposing themselves to the possible legal enforcement action that might occur should they fail to perperly disclose on some future occasion. We aren't against rule making as a concept but compulsory disclosure rules inject a big compliance risk into the business The seven day waiting period is totally unreasonable for the amounts of money involved, customer obligation, and the different motivations prospects have for wanting to register. Please leave these burdensome provisions out of the rules. Thank you in advance for your consideration.