|Received:||7/6/2006 1:00:32 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Issue #1 A prospect wanting to register with our business has to wait 3-7 days to register. This is unfair to the potential business owner who wants to start now. It's an unfair financial burden to delay their income. Additionally, our personal business has about 300 new business owners added each month. To delay each 3 days represents 900 business days per month of business loss. Quixtar.com adds 20,000 new business owners per month which correlates to 720,000 lost business days per year. When the commission was estimating compliance cost this was not considered. We offer an unconditional satisfaction money back guarantee. No one is at risk. Solution-illiminate waiting period. Issue #2 For Quixtar and/or me as a business owner to be required to give a prospect a list of references is poor business practice. This will cause us to lose money and business. The people we would give as references would also be competitors. Solution-eliminate the requirement to provide 10 references. Issure #3 Giving a prospect a list of all legal claims or actions for the past 10 years would be inappropriate, as anyone could be falsely accoused or could settle, as a smart financial or business decision. A crook won't mark the correct box anyway. If a judge who handled a claim thought they needed additional exposure he would mandate it. We shouldn't mandate that kind of exposure. Solution- illiminate the requirement to disclose past litigation. Issue #4 Making a different disclosure for every income claim. If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for "active" IBO's . Issue #5 Require to give prospects with financial documents to back up any income claim. Solution-IBO's should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation.