|Received:||7/17/2006 11:05:25 PM|
|Commenter:||Devington & Edmarie Fletcher|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:1. Eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied. 2. Eliminate the requirement to provide 10 references. 3. Eliminate the requirement to disclose past litigation. 4. If disclosures are needed, require a simple,standard,easily understood disclosure such as "average monthly gross income for 'active' Indipendent Business Owners." 5. Indipendent Business Owners should possess substantiation for any cliam but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation.