|Received:||7/1/2006 9:50:03 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have concerns about * an unduly burdensome disclosure document that 1) requires a seven-day waiting period prior to being able to register a new IBO because a) there is already the ability to cancel if they want to do so, and 2) the cost to register is only $31. Anything else they buy is purely optional. So the cost is minimal. No risk here... spend that much to go out for dinner. * I also have concerns about the 10 IBO references in the area. That is a problem for new IBOs who may not have 10 people registered yet. We can take them to a meeting where they can meet people, sometimes out of town, but I don't feel it should be a requirement. Often hard to get a new person interested in attending a meeting right away. * Listing all lawsuits, arbitrations, and legal claims against Quixtar seems silly. How many other companies do that when they hire employees? And again, the only amount that the IBO is out is the registration fee. * Requiring new IBOs to calculate and make diffrrent disclosures for every income claim seems a bit out of reach for most of the newer IBOs. The ability to do the calculations are all printed, and available to view. I would sure hate to try to figure it all out myself. * Same with providing "substantiation" for every income claim. The opportunity in this business exists to make a little money, a lot of money, or no money. Ultimately it is like any other business endeavor - you get back out of it what you put into it. The business does not work itself, you have to work it... put forth the effort. It requires a lot of work to make it successful. MY RECOMMENDATIONS ARE: * Should creaqte a level playing field by requiring clear, simple, and standardized income disclosures that apply to all direct sellers. * Should provide a reasonable cancellation policy. * Should not require a seven-day waiting period before prospects or disclosure of past litigation. Should not require financial records to be disclosed to prospects.