|Received:||7/17/2006 5:10:57 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To whom it may concern: My wife and I have been Quixtar IBOs (and formerly Amway Distributors) for over 14 years. To date, the primary benefits we have gained in this endeavor have been a direct result of the sound business and life principles taught by the founders and the mentors in our line of sponsorship. I have enabled my wife to stay at home and be a full-time Mom to our children, as well as eliminating all personal debt outside of a small remainder on our home mortgage. The business plan delivers exactly as advertised, and I fully expect to reap increased financial rewards as I make the commitment to invest more consistent time and effort in building our business. This is not a get rich quick scheme, and we do not represent the business plan as such; it is a simple plan, but requires effort nonetheless. I appreciate any attempt by the FTC to protect business prospects from unscrupulous operators, but I feel our Quixtar IBO-ship is already sufficiently regulated, and am concerned about the new provisions in this proposal: * Seven-day waiting period: I fail to see the benefit of this restriction, especially in a business such as ours where satisfaction is guaranteed, and any sign-up "fees" would be refunded if a new IBO were dissatisfied for some reason. The implementation of a waiting period would only serve to frustrate new business owners and their sponsors alike, since an artificial limit would be imposed on their ability to begin building that business. This proposal would also be cumbersome on sponsors to implement, necessitating the tracking of "eligibility dates", and inviting the subversion of the waiting period itself for highly motivated business builders. * References: We already routinely introduce prospects to other IBOs in our line of sponsorship, thereby leveraging the collective life and business experiences and viewpoints of the "system" in the process. The requirement to provide personal information on those IBOs would be an unnecessary invasion of their privacy rights. *Litigation list: This requirement is too broad, and I am concerned that any such list is likely to include numerous cases which are completely without merit, which would unnecessarily mar the image of an honest and forthright business. *Specific earnings disclosures: We already share FTC-approved earnings statistics via the form SA4400. *Financial substantiation: As with the requirement to provide references, I believe this aspect is an invasion of privacy. Further, since our business is satisfaction guaranteed anyway, if we were found to be hiding information or misleading prospects/IBOs they already have recourse to recoup their investment. We take a long-term approach to business development, so this breach of trust would only serve to undermine our own business expansion plans. Note that "traditional" business vehicles, as well as employer/employee relationships have no such requirement placed upon them by the FTC. Thank you for providing a convenient medium for submitting feedback on this proposal.