Comment Number: 522418-12580
Received: 7/17/2006 11:01:02 PM
Organization:
Commenter: Marshall Loos
State: NY
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

We have been IBO's for over 30 years and we have been able to replace one of our incomes for over 25 years. When we registered as IBO's we were informed it wasn't a get rich quick scheme and it would require consistent effort. We make sure anyone registering today understands the same thing. We provide every prospect with an SA-4400 which shows income averages and statistics. We explain to prospects what level of achievement we have reached, but do not disclose our monthly or yearly income, nor should we. It's really no ones business how much money we make anymore than everyone at the FTC disclosing how much money they make. Because we have been able to more than meet our needs, we have been able to donate money to churches and charities and thankfully the only requirement for reporting that is the IRS. When registering new IBO's their investment is someplace between $100 and $300 based on their needs and desires. It was $35 for us to register 30 years ago and figuring inflation, todays investment is about the same. We believe the 7 day waiting period would have an adverse effect for a number of reasons: 1st - is the fact we can purchase a $70, 000 automobile with no waiting period (requires a decision), 2nd - it delays the start of the new persons business and we know from statistics the sooner someone is successful (profitable) the more stable their business becomes, 3rd - it would increase our expenses because we would need to return to help them get started, 4th - this requirement would significantly slow our progress, as each and every IBO would have to wait 7 days to get started. The requirements to provide references and specific earnings disclosure is an invasion of privacy, We certainly don't want others using us as references and we don't want to use others as references either. We have a monthly meeting where prospects and new IBO's can meet our Business Support team. These are the IBO's who they will be associated with and will be helping them develop their business. It's a good environment to observe and evaluate the character and commitment of the team. The requirement to provide a "litigation list" is almost absurd. We have worked for Fortune 500 companies that have "pending litigation" from many different sources including the Federal government. Some of this litigation is legitimate and some of it is completely unwarranted. How do you differentiate between the two and what purpose does it serve. Are you saying because these companies have a "litigation list" they are bad companies? If so, how did IBM, Boeing, Mobil or Lockheed Martin become successful or serve as many people as they have? We understand your concern for people being taken advantage of by unscrupulous companies or organizations, but this isn't the way to do it. This only penalizes the people who aren't dishonest from developing stable, successful businesses through hard work and commitment. Thank you for your consideration.