|Received:||6/26/2006 3:30:39 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an Independent Business Owner (IBO) with Quixtar and its successor Amway for over 10 years. I have been able to earn a secondary income that has helped my family during unexpected job transitions and medical expenses. My wife and I plan on continuing to grow our business to replace her job income, therfore we can start a family with her as a stay at home mother. In addition to the financial benefits, we have been able to build a network of people to provide a social safety net to our family during life’s challenges. I had sufficient information to make a decision to try the Quixtar business when I started. If I had ever chosen to resign my business the money-back guarantees offered by Quixtar where reasonable and satisfactory. The proposed seven day waiting period would negatively impact my registering new Ibo’s. A waiting period creates a false atmosphere of doubt and sigma about the business opportunity. The money-back guarantees offered by Quixtar as sufficient. The proposed requirement to provide references would negatively impact my business by opening my contacts and referrals to unfair market competition. My prospects have adequate opportunity to personally get references from 100’s of people during my weekly business opportunity presentations. The proposal to require me to provide a list of litigation would be prohibitively complex and confusing. Most lay people lack to ability to differentiate the difference between actual court judgments and cases filed without merit. I cannot support the proposal to require more specific financial disclosures and financial substantiation, as this would disclose too much personal finical information. Quixtar has always provided to me financial disclosures to share with my prospects that are adequate. In conclusion, I support efforts of the FTC to create a level playing field by requiring clear, simple and standardized income disclosures that apply to all direct sellers. The business opportunity should provide a reasonable cancellation policy. The disclosure policy and cancellation policy current in-place at Quixtar are sufficient and should be a model for the entire direct selling industry.