|Received:||7/17/2006 7:37:15 PM|
|Organization:||World Information Network|
|Commenter:||D. Keith Anderson|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My perspective is from an Independent Business Owner of 17 years affilliated with the Quixtar Order Consolidation Site and a Kansas District Court Judge of 24 years (now retired). LEVEL PLAYING FIELD: I support across the board fair level playing field among all business opportunity solicitations. DISCLOSURE OF PAST LITIGATION: No court of law would allow a prior arrest (which is only an allegation) to be presented to prove propensity to commit a current charged crime. It's beyond my comprehension an IBO would be required to disclose past claims or litigation against Quixtar or another IBO. My business has no relation to anything Quixtar corporation or any other IBO allegedly did in the past. That's the nature of my own "independent business ownership." I own it, not Quixtar. Quixtar corporation is only the place I order products for shipment of products to Independent Business Owners (IBOs) in my organization. It makes no sense to present to a prospect implied suggestion something someone not even connected with my business was accused of doing wrong. 7 DAY WAITING PERIOD: Let the market place determine selling and buying inclinations. If the government decides it needs to protect consumers, it would be more fair to all parties and accomplish the same thing, to allow a 7 day cancellation period. IBO REFERENCES: It would accomplish nothing. There are several hundred happy and satisfied IBOs in my business. 10 would gladly respond positively to inquiries. What would be the benefit? Such a requirement would be unconstitutionally limiting if I was required to furnish a list of 10 IBO referenced in a new "area" where there were no IBOs. DISCLOSURE CALCULATIONS FOR EVERY INCOME CLAIM: If that was possible, it would probably require a catalog sized document, our business offering such a wonderful variety of income opportunities. It would have no practical benefit for most prospects who have specific income desires. SUBSTANTIATION FOR EVERY INCOME CLAIM: If that means someone achieved such levels, that could be done. It might benefit prospecting IBOs with added verification of success. It has been my understanding we have been prohibited by the FTC in the past from presenting such information. Even though it would give more verfication and power for the presenter, it seems to me to be an odd requirement if the intent of requirements is to protect consuming prospects.