|Received:||7/3/2006 2:29:37 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife, Myrna, and I have been IBOs for about 14 years with the World Wide Group dealing with Amway, then Quixtar products & services. No, we haven’t made lots of money, our own fault for not following the guide lines and programs that World Wide laid out. But we do make money and the products and services are second to none. Our business is starting to grow due to the internet, which I look forward too. Regarding some of the possible rules that are being considered, I have to voice my concern. A. 7 DAY WAITING PERIOD. Not good. We normally get back to prospects 2 to 3 days after they have seen the plan. We not only want them to be excited about the program, but above all we want them to check it out so they know it takes time, 5 to 15 hrs per week, and it may take 2 to 5 years to reach strong 5 or 6 figure incomes. Provided they follow the program and have help from their up-line and World Wide. (Which I didn’t do, until recently). A. 1. Besides many don’t want to wait the 2 to 3 days. They see many fortune 500 companies and other well known brand name companies who have partnered with Quixtar and know these companies have checked out Quixtar more throughly then they could. B. 10 REFERENCES. Not good. If I ran a scam, you know I’d pay 10 people or more to be references. Another thing that’s bad about references, the people who one would use as a reference, well, they wouldn’t have a life other then a phone in their ear. C. 10 YEAR LIST OF LAW SUITES. Not good. Every large company has, or is having, some type of judgement filed against them. Yes some are valid and legal action is justified. Yet may are not, ie; a lawyer who just wants to go after deep pockets. Or a person who is a lazy slug and blames everyone else for failures in his life, but takes no blame himself. Anyone who runs a scam isn’t going to abide with that regulation. Or any of the FTC rules. Please don’t impose something that could lead to false claims and misunderstanding. Go after the scamers and shut them down, not just a slap on the wrist with a cease & desist, but lock them up and have them pay back the people they scammed. D. DIFFERENT DISCLOSURE FOR EVERY INCOME. I don’t know about other companies, but Quixtar has a “average monthly gross income for active IBOs”. When we explain that, the prospect knows if you do something, something will happen. If you don’t, then nothing happens. They understand they have to work and follow a proven plan if they want a monetary return. E. PERSONAL FINANCIAL STATEMENTS. I don’t care if I make 10 cents or 10 billion dollars, it’s not any bodies business except the IRS and the state. If someone asks me “how much are you making”. My reply is “If my income will determine your decision, I’m talking to the wrong person.” I understand you (FTC) want to clean up a large problem. I’m in favor of that, providing it doesn’t hinder us (Quixtar), which I believe some of the possible proposed rules could do. I don’t know if an “FTC Scale” can be implemented for control and monitoring, via your website, since I don’t know how the FTC works. Some thoughts. 1. List all companies that have FTC approval. (Might be a need for a 1 to 10 type classification) 2. List all companies that may be in a grey type area. 3. List all companies that you have legal/ethical problems with, or have shut down and who their officers are/were. 4. Have a section on your site for people who have been offered a business opportunity by a newly formed company that is not listed by the FTC. Then they can enter the name of the company, product/service, etc info into your system for monitoring. It may be an advantages for the FTC if it were required that all business opportunities presented, then the prospect would receive FTC contact info. I know you have to protect the public, but in the same light you need to protect well established companies who abide by the FTC rules and are an asset to the US economy.