| Comment Number: | 522418-10930 |
| Received: | 7/17/2006 12:10:41 AM |
| Organization: | M & D Enterprises |
| Commenter: | Michael Richey |
| State: | KS |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom it may Concern, I am writing in response to the Proposed rule for private franchising. There are several problems with this, First - Making Business ownerswait seven days before registering after reading disclosures will eliminate the waiting period for a prospect to receive their money back if they are unsatisfied. Second - Giving out a list of refernces will infringe on privacy right of other IBO's. Third - Giving a list of lawsuits and arbitrations would only open up doors for false accusations for many company's. Also, making a disclosure statement for every income claim is not practical, If a disclosure is required it would be better to come up with a standard disclosure that has average gross income for Active IBO's. And Last, Providing prospects with personal financial documents to substantiate income is unreasonable. An IBO should always posess documentation to this effect, but should not be forced to disclose it unless required by the FTC or other state agencies. I do support the general objective of what the FTC is trying to accomplish, however I think there are less burdensome ways to accomplish these tasks. Quixtar already provides prospective IBO's with extensive information before they register. Sincerely, Mike Richey