|Received:||7/17/2006 12:44:08 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have serious concerns about the proposed rule to require business owners to provide every prospect a list of "references" - contact information for 10 other business owners in the area - seven days before the prospect registers. 1) I am very sensitive to privacy of other business owners. 2) A business for one person will not be the same as for the other person (different goals, needs, etc). 3) I am sensitive to cross-lining between other business owners. It is extremely detrimental to many people in killing the opportunity for them by getting misinformation from another party who has no vested interest in the prospect's success. Another disclosure that is ridiculous is the proposal to list all legal allegations - including lawsuits, arbitrations and other legal claims - against a business and any of its business owners from the past 10 years. This proposal is totally unrealistic for a large company to maintain. We are IBO's with a fantastic company - Quixtar. They have been on the leading edge of business for a long-long time. Through our ten years of association with Quixtar and its parent company, Alticor, we have seen nothing but integrity, honesty and forthright communication. Even so, we know that many frivolous and unwarranted lawsuits have been attempted against these companies. It concerns me that just because a lawsuit is filed, it would need to be disclosed. Then, later when the lawsuit is thrown out of court because it has no merit - it would affect my personal business in a negative - and I had nothing to do with it. Also, doesn't the law say that you are innocent - until proven guilty? The proposal to prohibit prospects from registering as business owners until seven days after they receive a disclosure document is not necessary. Any reputable company will offer a money back guarantee if someone is not satisfied - within a reasonable time frame. Over the years, we have had a few people change their minds after registering - they were all happily refunded. You see, what you don't understand is that in our industry, if we let someone register and then they are not satisfied, it does us no good. We don't want two things, someone that talks bad about our business model or talks bad about us. We pride ourselves in our integrity to do the right thing. The proposal to require business owners to calculate and make different disclosures for every income claim is unduly burdensome. While we utilize a company approved plan to show potential incomes, for different situations and individuals, given their goals and desires, it may be necessary and appropriate to discuss other possibilities. It is not practical or timely to calculate out for them each different scenario. However, I have had prospects ask me to do so and then I will! We do not support and strongly discourage the proposal to disclose financial records with prospects. All I have to say about this subject is - for each person involved with coming up with that bad idea - we would like you to post your tax returns on the internet every year for the entire world to see. Yes - your right - that's no one else's business but your's. I thought that the government was so concerned about protecting people's right to privacy - well this proposal doesn't come close to achieving that. Let's just say - it is an extremely bad idea. As independent business owners, we are encouraged by some aspects of the proposal. We do believe that the overall objective should be to create a level playing field by requiring clear, simple, and standardized income disclosures that apply to all direct sellers. All companies should be required to provide a reasonable cancellation policy. Our business has changed our lives for the better. This proposed rule will threaten to impose undue hardship on us. We ask for a more reasonable approach to be taken. Thank you for your attention and consideration to this response.