|Received:||6/28/2006 10:43:36 AM|
|Commenter:||Kyeung Ho Oh|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:First, I would like to make my points as clearly as possible in a numbered order as below, then I would spend more space for my opinion. 1.I am for clear, simple and standardized income disclosure. 2.I am for a reasonable cancellation, and product return policy. 3.I am against a seven-day waiting period before a registration of new prospects. 4.I am against the proposal of requirement of disclosure of past 10 years of legal issues 5. I am against the disclosure of individual direct sellers's income to prospects. I believe that this proposal is meaningful in that it would prohibit illegal, unethical, bogus business opportunities from prospering over uninformed consumers and business prospects. So I believe that the rule should require clear, simple and standardized income disclosures, and provide a reasonable cancellation policy, and product return policy. But, I am against the proposed seven-day waiting period before a prospect could register because it would seriously hurt my business by delaying the pace of business, and causing redundant follow-up calls and appointments. Quixtar, the company I work with, would not be affected much by the proposed requirement of disclosures of past 10 years litigation. But, I am still against the proposed requirement that IBO references be provided to propects or disclosures of past 10 years of all litigations in that this proposal, if effected, would create an unlevel playing field for a legal, and healthy direct selling industry compared to other industries. I wonder how many people looking for a new business opportunity either in a direct selling industry or in other conventional industries could make a right decision for the new venture when they should focus on the past litigations and all the problems, rather than focusing on the possibility of the business. How many other industries are providing to their prospects with all the past litigations when they propose a business opportunity to them? Do franchising industries let their business prospects focus on their history of past legal issues so their prospects get confused with whether to start the business or not? What about other traditional businesses that have been playing critical roles for our country's financial prosperity? Even the US government would have no citizen to support and follow its common causes if the government should provide all the past problems and litigations to its citizens whenever it proposes new rules and directions. Finally, I am against the proposal that require financial records to be disclosed prospect for every IBO income claim. The comany I work with, Quixtar has already plainly writes the average income of IBOs and even average monthly income of all registered IBOs in the US even though those statistics and numbers are not a good indicator since it ignores the individual IBOs' effors and time to earn their income. I believe that it makes no sense when people shy away from the potential only by looking at the statistics which have no way to evaluate between the income and the effort and time associated with the income. Finally, it is against individual direct sellers' privacy if they are required to disclosure their income for every month to every prospect. I believe that whether or not they talk about their income to prospects should be their discretion. Thank you for your time reviewing my points.