Comment Number: 522418-04745
Received: 6/28/2006 8:54:33 AM
Organization: Quixtar
Commenter: Mark Miller
State: WV
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

First of all i would like to thank you for taking these steps for attempting to "clean up" the Franchise/Business Op. arena. I just have a couple of comments on your proposed legislation. 1) I would not have a problem with suppling a prospective business partner with 10 references in the area. But I don't think that would be fair to any of the 10 references. If I was a reference i would not want my privacy rights fringed upon. I have little children and with the society we live in today I am protective on who i allow to come near them. I would not like to have to give my address out to people i do not know. I also would not mind talking to prospective business partners, but if i were to receive 10-20 calls a week, that would not be appropiate. 2) The idea for specific earnings disclosures is great. I already do that with my prospective partners. 3) The requirement for financial substantiation is a good idea, but i do not believe it would be fair to someone new to the opportunity. In my case, i never understood what it took to be a business owner when i started. So it took me a couple of months to help my personal skills with selling products and talking with people. So this rule would have hurt my chances of expanding my business. I believe what we (quixtar) currently do is great, by providing average income figures for different levels should be OK. 4) One other addition to your legislation should be to not allow outside or 3rd-pary companies to profit from the education of business owners. For Example, one of the major causes for lawsuits in our business (Quixtar) is the compaint that Business Owners within Quixtar profit from the sale of books, CD's and other educational materials since Quixtar does not. Some foreign countries do not allow this with our business. Singapore is a great example. Or just requiring companies like Quixtar to sell the educational CD's & Books themselves. Thanks for what you are doing. There are a lot of people who are attempting to build business with integrity. And I hope my opinions help. Thanks Mark Miller