|Received:||6/28/2006 9:48:25 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I'd like to start out by saying that the Quixtar opportunity has greatly impacted my family over the past several years. Due to that fact, I'd like to comment on some of the new rules that are being proposed that would affect our busines. First: the requirement of a 7 day waiting period. Since the vast majority of the already small investment (under $150) is refundable, I'm not sure what benefit there is for the 7 day period. I would like to see that eliminated. It just doesn't really seem to benefit anyone. This is a dramatically smaller investment that buying a car--but there's no 7 day wait when purchasing an automobile. It just seems to unnecessarily single out our type of business. Second: The requirement to provide references. I believe that most people end up working with us/shopping from us because they like my wife and I. It's a relationship based business and giving those 10 references wouldn't really help anyone. And what would happen if someone is brand new and didn't have 10 references in their organization--would they need to give out names and numbers of individuals in crossline organizations? I think that would be a tremendous hassle, and different organizations and individuals operate their business differently. (we are INDEPENDENT business owners) I wouldn't want to rely on other people that I may or may not have a relationship with (in other organizations) to give my prospect proper information. The integrity of my business rests on MY shoulders, not other people's. Also--I would think that it would be an invasion of privacy. When going on a job interview, and applicant wouldn't get 10 other employee's personal information. It would be a clear privacy issue in that case, so I don't see how this is any different. Third: Litigation list. I think that's ridiculous, honestly. Every company that's over a billion dollars gets sued, but there's no way you could have Microsoft or Wal-Mart disclose a list of the thousands and thousands of cases against them for every potential applicant for employment. I just don't see the value that gives anyone. If every other company in America needed to do that, then I would assume we'd follow suit. But most people aren't going to read through hundreds of pages of legal jargon, and none of it has anything to do with me, as an independent. I have not been sued, my upline has not--so lawsuits against other people that have nothing to do with my independent business really should have nothing to do with my prospect. Fourth: Specific income disclosure. I worked for Robert Half International, a public 3+billion dollar company. People there told me what so and so made, what I would make, etc too. If we need to disclose then every other 'sales' organization should have to do the same. I think that's totally unreasonable to do that. A statement (like we already are required to make) of "the average gross monthly income...." is perfectly reasonable and I think enough. Fifth: requirement of Financial substantiation. I think that would be a clear invasion of privacy. Again, I can't think of another company in America where the hiring manager would have to disclose their personal earnings, and I've been a recruiter for 6 years. I agree, people should be honest, and not exaggerate, but I think that's an invasion of personal privacy.