| Comment Number: | 522418-04554 |
| Received: | 6/27/2006 11:49:23 AM |
| Organization: | GMD Enterprise |
| Commenter: | Maritta Loo-Sumner |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: "Business Opportunity Rule, R511993" As a small independent business owner within Quixtar, I am sincerely interested in your proposal. I applaud the efforts to provide appropriate protection to the public. There are some points however, I would like to address that would negatively impact my business. The requirement of a 7-day waiting period would have a detrimental impact on new prospects. The need to connect with the process and products is imparitive for a solid relationship beginning. Those less reputable business opportunities would quickly find a way to minipulate the intent of this aspect and the rest of us trying to work within the perimeters would be unable to engage direct and indirect prospects with the work process. The internet has provided us with the speed of now and the public has the expectation of that speed. Pre sign-up information has already ranged on an average of three to seven days where we have exchanged the full range of information about the business. If they decide a Quixtar business is not for them after they have registured, they can they get their money back. The requirement to provide references would seem on surface to be reasonable. However with all the challenges of personal information it is not reasonable to request others to provide information to strangers, nor am I comfortable with such an open door for my personal information. There are multiple opportunities for interaction with other independent business owners (IBO's), upline and downline. It is through the that system --the people---that the education process is developed. The Requirement to provide a "Litigation List" again has many negative repercussions that have nothing to do with the business opportunity. Again the privacy impact is far reaching beyond the intent of the proposed rule. It would have negative impact on new IOB's as the need for them to connect with a business that requires minimal upfront finacial obligation to provide full disclosure is not porportional. I noted that this would also not be limited to cases found against the seller but even filed cases with no merit. The requirement for specific earnings disclosures is openly discussed such as the average monthly gross income, SA-4400. But to openly state the earnings, especially new prospects, would unfailrly hamper the growth necessary to have a reasonable income. One can easily see my lifestyle, but new start-ups manytimes need to grow more before that impact is seen. Besides the growth and the benefits are far beyond the income. The business and personal values are greatly impacted and that growth will not occur if there are the disclosure barriers. My personal income is reported to IRS and I know of few individuals that would welcome others reviewing that information. Thank you for the opportunity to state my view on this porposal.