| Comment Number: | 522418-12718 |
| Received: | 7/17/2006 11:48:06 PM |
| Organization: | Quixtar |
| Commenter: | sydney williams |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-12718.pdf Download Adobe Reader |
Comments:
Eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied. Eliminate the requirement to provide 10 references. Eliminate the requirement to disclose past litigation. If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation.