| Comment Number: | 522418-05934 |
| Received: | 7/4/2006 2:08:36 PM |
| Organization: | iTeam-affiliated with Quixtar, Inc. |
| Commenter: | Yitz Weiss |
| State: | NJ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: Thank you for endeavoring to provide proper regulations and controls to insure that our industry is not flooded by scammers and schemers who continue to decieve the public about opportunities and business ideas. I believe the proposed regulations represent a valiant attempt to achieve those end results. However, the proposals as they stand would severely restrict our ability to properly assist those wanting to join this great opportunity. Specifically, I'd like to address several issues: 1) The 7-day waiting period would place a severe limitation on our ability to help people get started in business. Many people excited about the opportunity are anxious to see some immediate results. Delaying the start would significantly dampen their enthusiasm and restrict our business growth. In a business as ours where a money-back-guarantee is available, placing restrictions by delaying for a time period should be unnecessary. 2) The list of references proposal would create a tremendous imposition on existing Members/Independent Business Owners (IBO's). In these times of caution when people are inundated by stories of identity theft, privacy is key in maintaining public trust. The knowledge that new IBO's might be contacted by prospects would deter many people from registering. The way I've built my business these past 14 years, I have made same available to my new prospects by inviting them to meet our team in local meetings ("open meetings"). The prospect was encouraged to come meet the team and determine for themselves their level of interest. Some prospects take advantage of that forum, some don't, but the prospect is given the opportunity to meet the team without imposing on anyone's privacy (those at the meeting expect to meet new people). 3) I believe the lawsuit disclosure will place a negative slant on prospect's attitudes by focusing them away from positive benefits onto unproven allegations. Anyone can file a lawsuit (in fact many have), no matter how frivolous, and cast dispersions. An individual considering a business idea is responsible to investigate fully for themselves. Regulating the way people must investigate any industry will hamper growth. 4) I believe that income disclosures are necessary, but should be standardized in easily understood, general terms. Average incomes could be disclosed, average effort expended to achieve those end results could be discussed. But to require a disclosure for every possible income scenario is burdensome and unnecessary. 5) Providing prospects personal financial documents substantiating income claims would severely restrict our growth ability. As mentioned previously, most people nowadays would be very hesitant to disclose personal information to the public. Knowing they'd be required to do same would deter prospects from joining and building this business. As mentioned previously, anyone investigating details about our opportunity is encouraged to research fully, but that should not be done by encroaching on the privacy of others. Thank you again for your efforts on our behalf. Sincerely, Yitzchak Weiss Independant Business Owner since 1992