Comment Number: 522418-11915
Received: 7/17/2006 4:41:20 PM
Organization: World Information Network
Commenter: Charles Libich
State: OK
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Please eliminate the 7 day waiting period requirement It's an unneccessary business restriction when people are trying to get their business started. They have enough obstacles. Please eliminate the requirement for references--that's like asking a doctor or lawyer to supply patient or client references. It's an obvious privacy violation. Please eliminate the impossible task of disclosing the past 10 years, alleged or legitimate, lawsuts/unfair claims to prospects. That would be like asking Burger King or McDonalds to provide such a list to every custormer before they made a purchase--It's an impossible and stupid rule. Please rewrite the rule so that companies could use independent third party companies to research and provide "average monthly gross income" for "active" IBO's. Requiring an IBO to provide prospects with personal financial documents to back up ("substantiate") any income claim. is rediculous EXCEPT, an IBO should possess substantiation for any claim made. But they should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. Again, this is an obviious privacy violation.