| Comment Number: | 522418-04699 |
| Received: | 6/28/2006 12:19:34 AM |
| Organization: | bDigital Systems - A business powered by Quixtar |
| Commenter: | Aaron Boylan |
| State: | NC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I agree with the efforts of the FTC to prevent fraudulent business claims and pyramid schemes. However, not at the expense of honest hard working Independent Business Owner's (IBO's). There are several issues that need to be reconsidered. “7 Day Waiting Period” What will a 7-day waiting period do but slow down growth? Quixtar will refund an IBO's money within the first 6 months in business. That seems to be a much better plan to ensure people aren’t taken on a false representation of a business opportunity. “Litigation List” Why would you require a disclosure that includes all of the lawsuits filed against a company that are without merit? Do you require Wal-Mart or Home Depot to disclose to their customers how many false claims have been filed against them in the form of lawsuits? If people don’t want to pursue this business opportunity they can simply call the corporation and get their money back again that option provides a better solution to ensuring this is a reputable company. They aren’t making billions of dollars off of $150 registration fees. They need to move product just as every other company in order to make money. “References” Why would you require a list of 10 other IBOs for references? I don’t want my name handed out to someone else’s prospect that will call me and ask a thousand questions about our business opportunity. That will infringe my right to privacy and disrupt my own efforts in building my business. We have a very simple easy to follow process for prospects to become educated about the opportunity. They have the ability to go to a class where a successful business owner presents an FTC approved business plan. The prospect also has the opportunity to meet many other IBO's and ask them questions. The Class is the venue where references and questions should occur not on my own time by phone calls from complete strangers. “Specific earnings disclosures / Financial substantiation” When I talk to people about this opportunity I make it very clear there is no guarantee, because I don’t know what effort they are willing to put into it. Since I don’t guarantee them an income I don’t feel obligated to disclose how much I am making personally. I do however let them know how much they can make if they follow the same path of those that are making a certain amount of money. My up-line has provided copies of his checks to me, I pass them along to my group as encouragement, but he shouldn’t be required by law to disclose his income statements to me or anyone else. I have shared copies of my checks to my team to let them know they can do the same thing. However that is to trusted people on my team who are legitimately interested in building their own business. They aren’t some stranger who has not really proven their trustworthiness to me yet. This would only serve to slow down growth and set a bad precedence for a business relationship. Please reconsider the actions you are about to take, as they will negatively impact many thousand IBOs who are achieving their goals and enjoying the fruits of this country’s capitalistic economic system. Maybe the FTCs efforts would be better spent in “Certifying” certain network marketing companies to ensure they are legitimate so the common public would understand that we are in fact not an illegal pyramid scheme. Sincerely, Aaron Boylan