| Comment Number: | 522418-11584 |
| Received: | 7/17/2006 1:35:20 PM |
| Organization: | Miller and Associates |
| Commenter: | Deneece Miller |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
The Business Opportunities Trade Rule Proposal is a great idea for protecting the public from those intending to rip off the public. As a former victim of this fraud, I am grateful for this proposal. However, as a current business owner I am concerned about several of the proposed points which will harm legitimate business opportunities such as I have been engaged in for over 10 years. The FTC itself has investigated and approved the Quixtar Inc opportunity and knows that it is a legitimate opportunity, with complete integrity and inherent safeguards against fraud. This business opportunity has given us benefits including, but not limited to, financial. Affiliation with Worldwide Dreambuilders has strengthened our marriage and family among many other benefits. This is not a "get rich quick" scheme, but an opportunity for each individual to receive rewards for their own hard work. This is explained in detail when the opportunity is presented to any prospect. It is required by the supplier (Quixtar) as well as our teaching and support organization (WWDB) to explain verbally and also in writing in the form SA4400. A seven-day waiting period would hinder a new business owner from realizing a rapid return on his investment and severely slow down the growth of his business by making his prospects also wait 7 days, and the chain reaction continues ad infinitum. This is unnecessary as there is a money back guarantee on all fees paid and even on any products purchased. Therefore, I reccommend that a waiting period NOT be required if the business offers a money back guarantee in writing. This will help eliminate the frauds, but not harm the legitimate businesses. Giving the prospect a list of references in the area is a cumbersome task at best, and presents privacy issues and integrity issues at worst. With WWDB, prospects are encouraged to attend briefings where there are hundreds of other business owners of proven integrity available for interview and questions. A legitimate business already has this available to prospects and a reference "rule" would simply hinder legitimate businesses. The likelyhood of a prospect calling these numbers is slim and would therefore be moot. Disclosures are already a part of every legitimate business and more detailed information is always available to anyone who wishes to pursue the information. I have personally never had a prospect or downline request such information. There is no sense in requiring us to fill our minds with superfluous information. Those who want to know do have access to the information. Giving a prospect a list of lawsuits is akin to telling a potential date every slanderous thing that was ever said about you, whether or not it was true. This opens the door for everyone with a bad attitude to attack legitimate businesses by slandering them on the www.bathroom wall. Certainly the FTC is aware that this problem already exists. Do a search on I Hate Walmart. or any other business. The bottom line is: don't throw the baby out with the bath water. Do not harm legitimate businesses while you are attempting to protect the public from frauds. Small business owners, including home bases businesses, are the backbone of our great country. Break them, and you break the United States. Legitimate businesses already have safeguards in place, and they inform prospects of their rights. Please reconsider the points I have mentioned that will harm those with valid opportunities. Thank you for your time. Curtis and Deneece Miller