|Received:||7/17/2006 4:36:35 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am an Independent Business Owner (IBO) with TEAM. We are affiliated with Quixtar - using Quixtar as our business model - note: we are not Quixtar. We are the fastest growing leadership development program in the US. As an IBO, I am in agreement that prospect IBO's should have information to make informed decisions. That said, I have concerns about some components of the Trade Regulation Rule on Business Opportunities that would impose crippling burdens on honest IBO's without doing anything to prevent deception and would limit my opportunity for free enterprise. I have included some solutions for those components: 1. Prospects waiting 7 days after receiving disclosures before they can register - Solution: eliminate the waiting period for opportunities like Quixtar where a prospect may get his/her money back if not satisfied. 2. Required to give every a prospect a list of 10 references in the area including names/addresses/phone numbers - Solution: Eliminate this requirement - this infringes upon the privacy of existing IBO's and could lead to other IBO's not affiliated with TEAM, being contacted and registering the prospect themselves - resulting in limiting my business opportunity. 3. IBO's provide prospects with personal financial documents to back up any income claim - Solution: IBO's should provide this information to the FTC and similar state agencies in an agency investigation. An IBO's income is based on their level of activity in a business and is no guarantee that a prospect will do the same amount of activity resulting in a specific level of income and therefore the information could be misleading to a prospect. 4. Provide different disclosures for every income claim - Solution: provide a simple, standard and easily understood disclosure such as average monthly gross income for active IBO's. It is important to provide prospects with correct and accurate information to allow them to make an informed decision. Any legal and honest business opportunity does that and backs up their business plan with a money back guarantee if not satisfied. I would question any business opportunity that did not offer a money back guarantee to prospects. Uniform, industry wide disclosure requirements would help shut down bogus business opportunities that try to mimic legitimate direct selling business opportunities.