|Received:||7/3/2006 10:12:30 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Although some regulation of these types of businesses may be necessary, I don't believe that the approach you are taking is responsible. Many multi-level organizations are making wild and unsubstantiated claims. However, Quixtar is noted for it's honesty and fairness. Apparently you have little understanding about how these businesses work, for implementing "your rules" would make it impossible for this business to continue and thrive. I think Quixtar has been exemplary for educating their distributors in proper business practices. Please look to them for proper rules of conduct which would be applicable to all multi-level marketing organizations. A professor of accounting doesn't know or understand how accounting is done in the real world. A professor of medicine doesn't know or understand how medicine is actually practiced day to day. Likewise, your best source of information would come from the IBOA board. They know what works and where the pitfalls are. It absolutely a surity that the government has no idea what is needed to allow these businesses to thrive, and still stay within the bounds of fairness and lack abuse. Please allow the IBOA board to guide you in your work. Some of your proposed rules, like having a person talk to 10 IBOs, are absolutely ridiculous. Try having any employee of any business talk to 10 people in that business. The time constraints alone are prohibitive. Government interference is just that. Generally, the market place weeds out most problems. I'd stick to that. Rules are difficult to enforce and encumber everyone which leads to wasted time and effort for no good purpose. Thank you for your consideration.