|Received:||6/29/2006 12:08:13 PM|
|Organization:||The MBD Group|
|Commenter:||Bill Durante II|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:“BUSINESS OPPORTUNITY RULE, R511993” In reference to the proposed "Business Opportunity Rule,R511993" I believe reasonable business disclosures should be fair and help consumers make wise choices after they do their own due diligence. Providing clear, simple, standardized incomes that apply to all direct sellers would help a new person determine if this is the income they would like to work for and achieve. The solution for this would be to provide an easily understandable disclosure showing the average monthly gross income for IBOs who are active. I believe a reasonable cancellation policy should be used, thus having to wait 7 days before registering as an IBO would not be needed. Requiring past 10 years litigations should not be required, for if a person does their own due diligence, they can find the information because it is all public record. Requiring IBOs or Quixtar to provide lawsuits, arbitration, or other legal claims where alleged fraud, misrepresentation, or unfair practices were allegedly claimed –regardless of whether they were true or not true would not be a benefit to a proposed prospect. Once again public records are available and due diligence would take care of this. I do not support the proposed rule of requiring IBO to disclose income claims. My business is private and my income is determined upon my own efforts whether it be good or bad is my determination. This proposal would violate my privacy. Providing a standardized income, as already provided by Quixtar, shows the best income potential for prospects. The proposal of providing a list of references of 10 other IBOs in the area would infringe on the privacy of every IBO whose name, address, and, phone number was provided, this would also subject my own business to unnecessary loss of potential business because any of the referred IBOs could register the prospect resulting in my loss. This should be eliminated in this rule.