Comment Number: 522418-06257
Received: 7/5/2006 7:58:03 PM
Organization:
Commenter: Scott Sorenson
State: FL
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear FTC: Over the past 14 years I have been involved in several ‘direct selling and multi-level marketing’ businesses. These businesses are ideal for me as they fit well with my personality and desire to work for myself. I started these businesses after reviewing their plans, of which I had received enough information to make an intelligent decision. I weighed the investment cost against the possible return I would receive for ‘active’ involvement. I have been satisfied and have gotten returns commensurate with my activities based on those plans. As an active IBO, I provide the details and disclosures of our business to every prospect including informing them that it will require effort and time and is not quick. Typically, people who choose to register with me invest an average of $135 for their start up materials, membership and samples of consumables, which our business is centered around. I don’t encourage anyone to purchase a large stockpile of inventory that they may or may not be able to sell. I do suggest that they purchase things that they would use and possibly choose a market that they want to specialize in and then only buy a small inventory to use as promotional samples and merchandise to sell. If they decide that the opportunity is not for them then they get 100% of their money back for their registration and any inventory. While I agree that prospects need reliable information prior to investing in a business; I believe that there are more efficient and less litigious ways to accomplish this goal. 1. No waiting period for registration. There’s no benefit to waiting for something you want, can afford and would like to actively work to accomplish your own goals when you feels it’s in your best interest after receiving legal disclosures and a 100% money back guarantee if not satisfied. Waiting kills people’s excitement after getting a chance to own a business and have the opportunity to develop it. 2 Eliminate the requirement for IBO references. It’s unfair to give a prospect the chance to register with someone else after I have invested my time, energy and money to cultivate that contact. It’s a violation of my privacy for other IBOs to give out my personal information. Being provided with legal disclosures and a money-back guarantee makes the IBO reference list unnecessary. Due to the relationships in our business, other IBOs, whose references would be given out, might register the prospect instead of me and affect the relationship process detrimentally causing distrust issues and less success probability for the prospect. It’s better for a prospect to meet IBOs at our weekly meetings where they can get input from others who are succeeding at various levels in our business. 3. Eliminate disclosure of past litigations. Dishonest companies will ignore the rule and cause unnecessary expenses for the legitimate companies. It will open the floodgates for false accusations to pour into our court system. It would be detrimental for my business if I had to spend time and money keeping up with every lawsuit that involved our parent company and/or every IBO, even if there were any merit. 4. Simplify the income disclosure to all ‘active’ IBOs average monthly income. The amount of money made by the prospect depends on their efforts. They would be remiss to gauge their success on my efforts. 5. Disclosure of income should not be required. That information should stay private unless an FTC investigation requires it. I usually let a prospect know my recent gain based on my efforts for the same time period. I explain how the opportunity has improved my life by making me more positive and how it has helped me to relate to others and help them solve problems. My finances are my business. Even if someone knows what I made, it doesn’t guarantee them the same results. That is still dependent on them. Thank you for considering the facts that will affect my business. Sincerely, Scott Sorenson