| Comment Number: | 522418-05428 |
| Received: | 7/1/2006 4:20:24 AM |
| Organization: | DeHaven Enterprises |
| Commenter: | Brad DeHaven |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My name is Brad DeHaven and I am writing in regards to the proposed Rule regarding Business opportunities. I have been in Quixtar for over 6 years and with tons of hard work now enjoy a business that supports my wife and 3 children. This business has become my 'career'. While I believe in the role of FTC, and reasonable legislation to ensure fair and honest business practices, I find the proposed rule unreasonable and complicated. Up to this point, I have serviced hundreds of customers and distributors who have been satisfied with their experience. People have joined my business network and started their own business for under $300. If they ever have a 'change of heart' Quixtar offers a full refund of their start up costs. This has always been a wonderful safeguard in case someone changes his or her mind. I believe a money back guarantee satisfies all concerns. The proposed rule would dramatically reduce my business efficiency in developing happy customers and satisfied distributors. The rule would bear an unduly amount of paperwork and time. I would find it almost impossible to continue my work in the direct sales industry if this rule was activated. If my prospects were investing $1,000 or more to start a business I could see how more safeguards might be prudent. But in my case, a $300. start up cost is not significant amount to bring a pile of paperwork and 7-day waiting period. Also, I would be happy to provide references, and often practice this today when I have a few willing references who wouldn't mind a phone call, but to provide a list in their area, I would be forced to violate the privacy of others. Earning disclosures are already printed on literature we share with prospects. (Avg. yearly income, etc.) This is totally acceptable and honest as it stands today. Thank you for your time and consideration. Brad DeHaven Quixtar IBO