|Received:||7/17/2006 9:14:15 PM|
|Organization:||BWW TEAM WITH QUIXTAR|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:In regards to the FTC proposal for the waiting period to register new IBO's. We would like to eliminate the waiting period, we live in a military community, we already would like our new people to see the business plan more than once, and alot of times there prospects have come with them to see the business and are ready to register at the same time. Alot of our people are deploying overseas and are trying to build there business rapidly so there family will be secure while they are gone. Every person that registers with our business also has the right to get there money back if they change there minds. In regards to the proposal about the 10 references. We believe that this would cross over the privacy act. Again we live in a military community, where alot of the references that someone might have that are deployed out of the country some in locations of military security. We live in this community and we could not give 10 references to anyone because of the same reason so how could we expect a new business owner come up with something we could not do ourselves. In regards to the proposal regarding list of all lawsuits. We already suggest that new people check out our company through the BBB website, and other websites that they can check out our company so we would like to eliminate the requirement to disclose the past litigations, dishonnest companies will ignore this ruling whereas our IBOs are honest hard working families. In regards to providing personal financial documents to prospects, we believe that this would cross over the privacy act. It is no one elses business what our personal financial status is. Businesses that are not home bassed do not disclose thier personal finances to anyone buying into thier franchises. We already disclose to new prospects average monthly gross income for "active" IBO'S as required by the FTC. As business owners we should possess substantiation for any claim but should not be required to disclose it except when required by the FTC or any State or Federal agencies for investigation reasons.