|Received:||6/29/2006 8:26:09 PM|
|Organization:||Quixtar.com (Ephatha International)|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To whom it may concern, I am very concerned about the proposed business opportunity rules. First of all as a business owner, consumer and employee I feel that it is an invasion of my privacy for a prospective client to ask me for my financial records, or the records of any of my collegues. Never in my career has it been ethical to dispose this type of personal information to an outside individual; nor has it ever been appropriate for me to request this information from any other business intity that I have ever worked with. I have worked in contract with the U. S. Army, as an independent contractor cleaning service and I was not asked for my financial statements. I also disagree with the propsed waiting period of 7 days before a prospect can get started with the quixtar opportunity. Our business model clearly states that any prospect that is not satisfied with the results of this opportunity can get their money back, no questions asked, within 6 months to a year of registering. There is obviously no need for a waiting period of 7 days when a prospect has 365 days to change their mind. I also object to the idea of giving out the personal contact information of 10 local business owners to prospects that are not familiar with the IBO's before hand. I am hesitant to give out the contact information of my friends not associated with my business to persons I am not thoroughly involved with, and I feel it is not appropriate to do the opposite to those within my business team. I also object to this particular rule because although we would like every business owner to operate with integrity and honesty, when considering human nature, that may not always be the case. This rule may cause undue temptation for business owners to register your prospect themselves instead of you. Another problem that I percieve with your proposed rule is with the need for business owners to provide prospects with past litigation statements. The problem with this is simple. People lie. Besides, there is ample opportunity for any IBO to research this information with your office or the BBB. This rule would also do very little to stop illigitimate opportunities from simply not complying. These proposed rules and others that I have read in your draft of the Business Opportunity Proposed Rules are not considerate of the legitimate opportunities that are out there. Even though I commend the FTC's efforts to protect individuals, this draft of the proposal inccurs undue hardships on the businesses that have done nothing but try to create a fair and legal opportunity for everyone involved.