|Received:||7/5/2006 11:07:40 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
|Attachment:||522418-06319.pdf Download Adobe Reader|
Comments:I applaud the efforts of the FTC to prevent unlawful business practices. I am in agreement, however, with the official responses posted at Quixtar.com. While it is important to maintain and strengthen the integrity of legitimate direct sales systems, my concern is that these new proposals may add unnecessary confusion, time, and expense that may cause hesitation for otherwise qualified prospective business owners. Worse yet, I fear that the proposal would only inconvenience honest companies while presenting little or no threat to those that operate fraudulently. In keeping with the electronic age, there is a continuous effort to streamline the sponsoring process while preserving accuracy and legality. Within the organization I work with, this period for a new business owner is structured and the time frame can vary depending on the individual and their needs. To make accommodations for the new regulations would add time to this process in training ourselves and then training the people we sponsor (most have never before taken on a business of their own) how and when to use word-for-word legal verbiage, literature, personal contact information of fellow business owners (a concern in its own right), etc. These added pressures could prove to be overwhelming for a prospect just meeting the team and getting his feet wet. Although I am not familiar with other organizations, Quixtar readily provides informative literature upon request. The required production of additional printed and electronic literature would create added cost for the businesses that maintain their legitimacy, whether it is to the corporations whose profits we share in, or directly to us business owners. Much of this industry’s appeal is the low initial investment. To some, $20 can make all the difference. Any expense that would trickle down may present an added deterrent to someone who, in reality, is in great need of a good opportunity. I hope that my brief statements have provided a personal, ground-level look at a couple of the concerns that the proposed rules present. I would encourage a close examination of the suggestions made by Quixtar (attached), because like the FTC, they have the interests of honest business as heart. Illegal business practices do need to be stopped, but in a way that will promote the prosperity of the legitimate ventures.