|Received:||7/3/2006 12:47:38 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Regarding FTC's Proposed Rulemaking (Business Opportunity Rule) my following comments are provided: (1) Rule making language should eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his or her money back if not satisfied. (2) The requirement to provide 10 references should be elimated. This requirement infringes on the privacy of every independent business owner whose name, address, and phone number was provided to prospects. It would also penalize the potential sponsor, who would be required to give his prospect contact information for 10 other IBOs, any of whom might be happy to register the prospect themselves. (2) The requirement to disclose past litigation should also be removed. Among other problems, this requirement would open Quixtar IBOs, as well as other legitimate companies to false accusations. Meanwhile, other dishonest companies would simply ignore the rule. (4) If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs". (5) IBOs should not be required to disclose financial documents except when required specifically by the FTC or other similar state agencies in an agency investigation. Quixtar has provided a quality business opportunity to entepreneurs since its founding in 1999 that is both honest and ethical, and is structured so that independent business owners can develop a business model that is a proven alternate to other business or job endeavors. While I believe that providing every prospect with important information about prior experiences is good for the entire direct selling industry, there are less burdensome ways to accomplish that goal rather than the manner set forth in the proposed FTC rule.