| Comment Number: | 522418-05754 |
| Received: | 7/3/2006 1:02:15 PM |
| Organization: | |
| Commenter: | MIKE REQUA |
| State: | SC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
THANK YOU IN ADVANCE FOR ENTERTAINING MY VIEWS REGARDING REGULATION CHANGES IN THE DIRECT SELLING BUSINESS. I'VE BEEN AN INDEPENDANT BUSINESS OWNER FOR 16 YEARS WITH QUIXTAR. A. REQUIREMENT OF A 7 DAY WAITING PERIOD: TYPICALLY, THIS REQUIREMENT WOULD NOT BE A BURDEN EXCEPT IN THE CASE OF A NEW IBO IN ANOTHER STATE. DUE TO DISTANCE, THERE IS ALWAYS A "WAITING PERIOD" FROM THE INITIAL PROPOSAL TO REGISTERING DUE TO TRAVEL TIME. I FEEL A STRONG RECOMMENDATION VS. A REGULATION WOULD BE MORE HELPFUL. B. THE REQUIREMENT TO PROVIDE REFERENCES: THIS IS, AND SHOULD BE THE CORNERSTONE OF ANY OPPORTUNITY. WE DO THIS BY INVITING PEOPLE TO COME TO US AT SAY A HOTEL MEETING OR A TEAM TRAINING SESSION. WE STRONGLY RECOMMEND PEOPLE TO MEET THE PEOPLE THEY WILL BE WORKING WITH. BUT TO REQUIRE REFERENCES WITH PHONE NUMBERS AND ADDRESSES BORDERS ON AN INVASION OF PRIVACY. PERSONALLY, I DON'T MIND ANSWERING PEOPLES QUESTIONS ON MY TEAM, BUT I HAVE NO BUSINESS DOING THIS FOR SOMEONE NOT AFFILIATED WITH ME WITHIN THE QUIXTAR BUSINESS. C. REQUIREMENT TO PROVIDE A "LITIGATION LIST": I SEE BIG PROBLEMS WITH THIS. NUMBER 1 IS THAT ANYONE CAN MAKE AN ALLEGATION IN A COMPLAINT. AS YOU MAY KNOW, IN CIVIL LITIGATION, MOST ALLEGATIONS ARE THROWN OUT PRIOR TO THE JURY HEARING A CASE OR CERTAINLY PRIOR TO THE JURY RETIRING TO THE JURY ROOM. IF YOU FEEL THIS IS NECESSARY, LIMIT IT TO SETTLED CASES. ALSO, A SIMPLE WEBSITE THAT LISTS THESE SETTLED CASES (SPECIFIC TO EACH COMPANY) COULD BE USED. D. REQUIREMENT FOR SPECIFIC EARNINGS DISCLOSURE: WE CURRENTLY USE FTC RULES FOR DISCLOSURE OF AVERAGE EARNINGS IN THE QUIXTAR BUSINESS. WITH THE EXCEPTION OF ELECTED OFFICIALS AND GOVERNMENT WORKERS, I AM NOT AWARE OF ANYONE BEING REQUIRED TO DISCLOSE THEIR PERSONAL EARNINGS. THIS IS TRULY AN INVASION OF PRIVACY AND HAS MORE POTENTIAL TO HARM A NEW PROSPECT THAN TO HELP. ONCE AGAIN, WE ALL USE VERY SPECIFIC EARNING LEVELS ALREADY OK'ED BY THE FTC AND ALL IBO'S ARE FREQUENTLY URGED TO USE THESE NUMBERS AND NOTHING ELSE. IT WOULD BE BETTER TO SEE THAT EVERY DIRECT SELLING BUSINESS PERFORMS THIS REQUIREMENT THE SAME AS QUIXTAR. THANKS YOU AGAIN FOR REVIEWING THIS INFORMATION. I WOULD WELCOME YOUR FURTHER INQUIRY BY PHONE SINCERELY, MIKE REQUA