|Received:||7/1/2006 6:23:12 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I started in the Amway business in 1996. We have used the business to supplement our income for years. I think the products are great and enjoy the people in the business. I started my business for only $125, and was told that it was not a "get-rich-quick scheme" and it would take time, energy, and committment to build. Working together with my wife has greatly helped us to communicate better and develop a strong marriage and family. Several others that are part of our business have had the same benefits. We recently made a quality decision to elevate our efforts and build a much bigger business. These rules proposed by the FTC on my business worry me about the additional burden placed on me to achieve success. For example, when I offer the business to people, I always use literature that shows average incomes that have been approved by the FTC and Quixtar. When I got started, I didn't need all kinds of disclosure statements because I could meet other people who are building the business in my area. I have direct access to my upline Emerald IBO and have had many opportunities to talk with my upline Diamond, very subtantial levels of success. I don't need their income statements. I can walk in their homes, ride in their cars, and hang out in their hot tub. I have met hundreds of other IBO's that are very satisfied with their businesses when I attend seminars and other very affordable business functions (typically for less than $30 per ticket). In Quixtar, we already offer people a money back guarantee for everything, from products to cost of registration. In fact, I remember getting a guy started and the next day he called me and returned is started kit because his wife told him he couldn't build it, no joke! He got his money back. The seven day rule would just slow down our growth. Besides more often than not, people take a week to listen to CD's about the business, or go to a business workshop in the area before even starting, and I encourage them to do so. I don't make money when they register, so if I sign them up and they quit, I lose my valuable time. Concerning the rule about providing 10 references: that will potentially harm me personally in two ways. First, I don't want some stranger calling my home. I have a wife and four young children. I know I show this business to complete strangers, so other IBO's do the same and, I don't let them get close until I know I can trust them. Second, if I do all the hard work to prospect and show the plan to new potential IBO, I don't want them calling other IBO's that I don't know and are not in my business, trying to steal my new person. That new prospect will get many chances to meet hundreds of other IBO's at the weekly business workshops before the commit any money. The need for references in our business is irrelevant. The rule about disclosing a litigation list is frustrating. The legal profession today is irresponsible at best. If a decision by a judge has been made concerning and IBO or Quixtar, then that is something to be reported, but today, in our highly political society, the legal system is being used to make false accusations in an attempt to damage good character. And, many times, these false accusations come from your competitors. That may be the most harmful rule of all of them. I did read most of the federal register on this subject. There was one part that talked about how many small companies just blatantly ignored the franchise rules because they thought that they couldn't afford to comply with them. So now we propose a bunch of new laws intended to shut down the bad guys...great idea in theory, but the bad guys still figure ways around them, while the good law abiding citizens and business owner are forced to comply with more burdening obligations. Maybe a better solution is educating people on making good decisions. I also had one person turn down Quixtar for vending machines...