|Received:||6/30/2006 12:39:49 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I applaud the FTC's efforts to ensure that the public is properly informed about opportunities such as ours. As such, I agree with much of the provisions in the proposed rule. For example, average income disclosures and reasonable cancellation policies are good things that should be provided to prospects. There are, however, some provisions of the new rule which are inappropriate and not only do not help the prospect but could actually hurt them. One of these is the waiting period with the requirement of references. While I do not believe in pressuring people with time limits, different individuals require different amounts of time to make educated decisions. In our business, some people are ready to go right after a short review of the facts and there is no question that this initial excitement plays a critical role in getting there business to a profitable level. A waiting period requirement could quench this excitement and result in months of stagnated growth. It actually hurts the potential of their new endeavor. A reasonable cancellation policy seems to be a sufficient safeguard to someone making an unwise decision based on excitement. I am always willing to provide more time and references for someone who requires these. Another area of concern is the submittal of all legal allegations. These lawsuits may not (and most likely do not) have anything to do with the individual who is recruiting a given prospect. Plus a lawsuit, by itself, is not evidence of wrongdoing on the part of the company. Most prospects are not lawyers and therefore do not have the capability of sorting through this information. Plus, the information is likely irrelevant to two parties conducting business. It seems to be the job of the FTC to follow such suits and shut down illegal operations. Finally, I think that average income disclosures are all that is needed regarding financial records. This levels that playing field and, as long as they are documented in the presentation literature, eliminates the possibility of false claims. Thank you for making is possible for me to voice my concerns and I appreciate your role in making my industry a safe one.