|Received:||7/17/2006 9:23:03 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I own an independent business using Quixtar, Inc. as my supplier. I have owned my business for 2 years and 3 months. I was provided sufficient information as a prospect to make a clear and informed business decision. I was able to do this without the restrictive rules proposed in the above mentioned executive order. It was made clear to me that my income would be tied directly to the amount of effort I applied. In my own prospecting, I have made the same information available. Upon seeing the commitment I was willing to make, many prospects were not willing to start their own business. In proposing a 7 day waiting period, the above order places an undue restriction on the immediate profitability of new prospects. Further, with the far-reaching money-back guarantees offered by many legitimate direct-selling organizations, a prospect is still allowed an out, should he find that the business opportunity is not meant for him. Requiring a list of 10 local references places an undue burden on the prospecting IBO, taking time away from developing a profitable business. This requirement will also invade the privacy of the listed IBOs, many of whom may not wish to be contacted by prospects of other IBOs. Despite using the same supplier, there is still a measure of competition. In the same manner, requiring the prospecting IBO to find all litigation involving the supplier company reduces the chance of profitability. Direct selling organizations provide a valuable service to the economy of the United States. Legitimate business opportunities allow the average person to put in effort in his spare time and create extra income. The increased income helps to increase his standard of living and allows more money to flow through the economy. Many opportunities are also available at a low-startup cost, which allows people in lower income brackets a way to decrease the growing income gap. In effect, these opportunities are the essence of what this country was built upon. With this in mind, requiring significant research on the part of the prospecting IBO reduces the time available to generate sales or prospect new sales team members, thereby reducing profitability. Furthermore, requiring prospecting IBOs to provide personal financial documents discriminates against these lower-income startups. Private corporations are not required by the FTC or SEC to provide financial statements. It reeks of classist discrimination when small sole-proprietorships are required to provide a greater measure of financial transparency when large private corporations are not. I am expressing my concern with the above regulation and would suggest that you do not place these restrictions on future IBOs.