Comment Number: 522418-05258
Received: 6/30/2006 11:18:35 AM
Organization: Quixtar
Commenter: Tim O'Dell
State: MI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

To Whom It May Concern at the FTC. The direct selling industry is one of the last area's where a person can genuinely own there own business, and build it to whatever level that they chose. The industry is built on personal responsibility and is grass roots free enterprise at it's finest. Please consider my comments below. Concerning Prospects waiting 7 days after receiving disclosures before they could register: This is unecessary as a form of consumer protection when a company already has a full money back guarentee if a prospect is no satisfied with there experience. I propose the waiting period be eliminated for those companies that have a money back policy already in place Concerning 10 name “reference list” : This is a potentail problem for the privacy of the 10 people that are used as references not to mention this would in effect be handing a potential customer of your business to your competition – I don’t know of any other business that is required to do that. There is currently any number of resuorces available for a prospect to get accurate information about the opportunity that they are interested in. I propose that this item be eliminated Concerning providing a prospect with a list of all legal claims for the last 10 years: This item would open up legitimate companies to unfair, unsubstantiated and false accusations. Illegitimate companies would simply ignore this rule. In effect you would be penalizing the legitimate companies. I propose that this item be eliminated Concerning Income Disclosures: For companies that already have disclosures for average incomes this should be eliminated. Provided that those disclosures also substantites and quantifies what the “average” means and some verbiage is added that the opportunity being evaluated is not “get rich quick” Concerning personal financial documentation to substantiate personal income claims: People should possess substantiation for any claim made but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation.