|Received:||7/17/2006 4:50:34 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:We have been independent business owners for quite some time, now. The FTC proposal has some good and not-so-good points. First of all, clear, standardized income disclo-sures that apply to ALL direct sellers is reasonable and would provide a level playing field. When we first became business owners, we were given average business figures. We didn't expect exact ones, naturally, as no one could obviously provide that kind of information, neither could they possibly guarantee anything. A reasonable cancellation policy is also a wise proposal. Not everyone becoming involved in a business has a clear picture of what they want, and a working business and not a get-rich-quick scheme may simply be more than some folks are will-ing to work for. We found at the beginning that it definitely took work to build and it took work to get and maintain good customers. That was all a part of business. With regard to a seven-day waiting period before someone actually registers in a business. . .this would be redundant and counter-productive if there were a reasonable cancel-lation policy in force, which in actuality, Quixtar does have and has always maintained. We were told that we were able to cancel our business registration the same as we would be able to return a product. We have been pleased at the goals we've been able to reach, the strength and insight that the training has provided, and the relationships we have been able to foster and maintain and never saw fit to relinquish our relationship with Quixtar. Concerning providing references to prospects and having them be able to canvass other business owners before they register with their original contact. . .this would be unduly competitive and punitive to the business owner who took the courage, time, money, and energy to make the contact. I see no pro-blem with providing prospective customers references to current clients. Neither should financial records be disclosed to prospects for much the same reason: some people might be unduly im-pressed (or distressed) by someone's finances which may or may not present an accurate picture. In addition, those re-cords should be confidential and private and you basically can't guarantee the information will be kept confidential. In a day and age of identity theft, that kind of proposal is simply unreasonable. . .and unwise. In these paragraphs I've tried to give a first-hand perspective of what this business means to us, the insights we've gained and the impact the proposals would have on our business and others' and some ideas on a better approach to reason-able regulation.