|Received:||7/6/2006 12:10:31 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Thank you for the opportunity to comment on this proposed rule. I applaud the FTC for working to reduce or eliminate the risk people face from fraudulent business opportunity scams. While I applaud your efforts, I have some specific concerns about the wording of the proposed rule. I have been involved with the Quixtar business since its inception in 1999. I have never felt coerced, cheated, or manipulated in any way. All of my dealings with the organization, both the corporation and my support team have been positive. I have found that the positive personal impact far outweighs the minimal investment to become involved in this business. People can get involved in this business for about $60. If they decide to do everything we recommend, the total initial investment would be about $300. Everything except the registration fee is fully refundable for up to six months, and I'm pretty sure that I could get the registration fee refunded if someone wanted to rescind their decision to register with Quixtar. There is minimal risk in joining this business. Everyone is provided information about potential income, average incomes, and expected expenses to run the business. Everyone decides their own level of participation in the business. My specific concerns: 7-Day waiting period - Because of the refund policy and information disclosures made at the time of presenting the business plan, I see no benefit to prospects in requiring a 7-day wait to register. However, I see this rule hurting the very people it is intended to help. Most people who start the business have limited financial resources - that's why many are attracted to this business. The 7-day waiting period would increase the expenses of people attempting to build the business through increased travel and communication requirements. It would unneccessarily delay the start of people who want to get going to generate income from the business. References - New business owners always have the opportunity to meet with other business owners at business events. We are a community, so we meet frequently. New business owners do not operate in isolation from other business owners, they work in concert with them. However, I don't want people giving my personal information to people I don't know so that I can spend my time answering questions for people that are interested in building the business with someone else. In effect, this would put me in a position to provide customer service for businesses from which I could derive no income. Litigation list - This requirement does little to protect people. It would just be a list with no framework for understanding the issues. Since anyone can file a suit, a simple list of allegations would only list claims made. It would do little to help people truly understand the opportunity and its associated risks. This requirement would cast a wide net that would probably screen out bogus businesses, but it would also hurt honest businesses because they could not fairly present their side of disputed issues. Financial Substantiation - I don't want to disclose my financial records to everyone I work with. The opportunity speaks for itself. It would be a violation of my privacy to require that I lay open my financial history to everyone I show the business to. I only ask if they are willing to work hard to accomplish a goal, I don't require that they show me their records to join the team. Why should I show them my records? Once again, thank you for working to eliminate bogus business opportunities. The Quixtar leadership team makes every reasonable effort to ensure that people are treated fairly and honestly. Please work with their legal and advisory staff to create a fair and reasonable rule that will level the playing field and protect both prospective business owners and those of us who are honestly working to build a profitable business with minimal overhead expense.