Comment Number: 522418-05881
Received: 7/4/2006 3:14:43 AM
Organization: Goodwin & Associates
Commenter: Anthony Goodwin
State: VA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing in regards to the proposed rules of the business opportunity. I have owned the rights to the distribution system of Quixtar/Amway as an IBO since 2003. I feel that the proposed rules are a good way to develop a security "net" to the general public. As for the proposals there are things that can be addressed that would effect on how we operate our invitation to do business with prospects. First the waiting period to sign up does not seem to create any security what so ever for example if a business opportunity were illegal or "shady" the waiting period would be built into the scam process. In fact the waiting period should only apply to programs that do not offer a full 100% money back guarantee that is well promoted and obvious in the presentation. As for the proposal of the 10 references of other Ibo’s. This would not be what we are promoting, but we are promoting the Distributing System of Quixtar and as stated clearly as national BBB member and also links business with a multitude of other well known retailers through out the country. These are the true “business references!" The rule proposed for earnings disclosure is already being carried out in the presentation of the business through the base average income of $115.00 per month. This rule is clear and is available in take home information after the presentation. The proposed rule of "litigation lists" can be only described as a way to muddy water that simply is not necessary. For few brief examples; I would like to buy a cup of coffee at McDonalds in which describes on the cup that the contents are hot, but should not say how many times McDonalds has been sued over someone getting burnt and by the way most of the time the lawsuit doesn't even include a refund for the spilt coffee. Full disclosures of purchasing stock in a company does not come right out and say that it is in a pending investigation for anything, and most of the time you have to make your decision by the closing bell, and try to get your money back if you didn't like the turnout the next day. In Closing I believe that if you give educated person information in which they can understand, and then they have the right to properly investigate it and study it as fast or as slow as they like before getting involved what so ever. Thank You, Anthony W. Goodwin