|Received:||7/17/2006 6:08:42 PM|
|Commenter:||Richard D. Yost|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:We began our Quixtar (Amway) business 37 years ago. We did so with the knowledge and trust of personal acquaintances. Having been an investigator in the past I did obtain a Dun & Bradstreet report on Amway to assess the corporation...but I did it on my own. This had been our primary business for over 34 year. We have alway operated in a legal, ethical, honest business method as illegal, unethical and dishonest don't last. The Quixtar ( Amway) opportunity has given us a very good lifestyle financially and otherwise. We never portray this as a "get rich" opportunity and always provide prospects with business and product information as well as the Quixtar web site for additional information. We live in a country which promotes Free Enterprise. If and when unethical business practices come to light they should be investigated and handled in a just manner against the perpatrator(s). The FTC proposal would hinder any little "start up" business opportunity...even the person that want to open a little buger stand and offered an investment or involement to several friends. The wise prospect would be wise to investigate the "opportunity" on their own. 1. The 7 day waiting period would cause confusion to prospects as to WHY, and also would permit prospect to seek out other Quixtar IBOs who may tell them they would be better off to register with them. Many times it is 7days or longer before a prospect registers due to various circumtances (work schedules, family obligatins, etc.)....but don't make it a RULE. Eliminate the waiting period ! 2. Give list of 10 "references" to prospect would infringe upon the privacy of each IBO whose information was supplied as well as the posiblity of proselytize them to their orginization. Eliminate requirement to provide 10 references 3. Give list of lawsuits, arbitrations or other legal claims for past 10 years. We have no way to research for this information. In 37 years there have been none againt me ! Since you are proposing this, why haven't you disclosed all such action againt the FTC ?? Eliminate requirement for disclosures of past litigations. 4. Discloser for every income claim. Nearly impossible as there are too many varialbes as to the structure of an organization. Only a standard, simple, understandable, example could be used to represent "average monthly gross income for an active IBO". 5. Personal financial documents. Not a sound business practice for any business ! This information should only be available to financial institution where loans, etc are being transcted or to IRS or ligimated investigative agency. For the new IBO, just establishing their business, there may litte or no net income. All that can be offered by the new IBO to a prospect is a projection of expected income based on the time and energy they will be allocating to their business. Please be open minded and realize what undue obligations the proposed rulings would incure.