| Comment Number: | 522418-04951 |
| Received: | 6/28/2006 10:21:46 PM |
| Organization: | Quixtar |
| Commenter: | Philip Haretos |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
In response to the proposed legislation regulating direct selling organizations, I would like to make the following statement. I have been a Quixtar/Amway independent business owner for the past 13 years. In such time, I have gained a tremendous level of respect for the leadership and business values upheld and taught by other Quixtar/Amway independent business owners and corporation. My experience has taught me that in direct sales and network marketing, it is only through the highest levels of honesty, integrity, transparency, and character that one can lead and partner with others, over a LONG TERM. Those individuals, organizations, and fraudulent businesses that practice deception are typically one day wonders. Today, through unwavering principles and character, we have been blessed with business partners in many countries around the world. Worldwide, Amway/Quixtar uphold the highest level of 'satisfaction guarantee' with an unparalleled return policy, even in foreign markets where they are not regulated to do so. Within days, dissatisfied participants can return their registration for a full and complete refund, including shipping (in most countries). As there is no 'profit' in a registration, there is no 'benefit' in keeping an unsatisfied partner's registration fee. My specific vote is to reject the proposed seven (7) day waiting period. Through a solid and 'no questions asked' 90 day return policy, the same objectives are met, well beyond the initial 7 days one is 'exposed' to the opportunity. An important element in the Quixtar business is the opportunity to 'test drive' the business for 90+ days to see if it is a good fit for the new member. Adding a 7 day waiting period would only delay and impede the complete decision making process. Do we need to wait 7 days to test drive a car or get married? It would be even more ridiculous to impose legislation to mandate a 7 day waiting period for a business that can be purchased and RETURNED for under $100. I also vote to reject the proposed legislation that would require to provide references. First off, this can be manipulated quite easily by the dishonest. Secondly, I enjoy my privacy and would not want it violated by federal legislation. Thirdly, the Amway/Quixtar business model is built as a team working together toward a common goal. It is not an independent action between one 'sponsor' and one 'downline.' Because the Amway/Quixtar business is traditionally built as a team, we encourage prospects to meet the ENTIRE team that will be helping them develop their business. Continuing the car example, it would be ridiculous for the car dealership or salesman to provide to the potential buyer a list of other car dealerships or previous buyers as references. The dealership is either creating his own competition or violating his previous clients' rights to privacy. I also vote to reject the proposed requirement to provide a litigation list. Who is to judge which cases were individual verses corporate malpractice or even frivolous, keep current the outcomes or appeals, etc, etc. The better thing to do is for the FTC to develop an annual 'rating system' based on its own research of the corporate practices and compliances to federal and state laws. For each direct selling/network marketing company the rating system should simply state: 1-Fails to meet, 2-Meets, 3-Exceeds federal and state regulations, etc. While I don't have the room to address all points of the proposed legislation, my overall feeling is that it has good intensions but GREATLY lacks the practical experience necessary to be effective and impartial while not impeding the spirit of capitalism. In my experience with the Amway/Quixtar organization and business worldwide, they have played a major role in expanding these ideologies. I implore you to work closely with them to find a meaningful solution. Sincerely, Philip Haretos