| Comment Number: | 522418-06490 |
| Received: | 7/6/2006 1:49:33 PM |
| Organization: | |
| Commenter: | Lauren Ramage |
| State: | SC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My name is Lauren Ramage and I have been working with Quixtar for the past four years. After reviewing the proposed rules to assist in consumers making a sound decision, I wanted to submit my opposing views. The first problem that caught my eye was that prospects would have to wait 7 days before registering. I propose that the waiting period be eliminated, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied. The FTC proposing that you would be required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other IBOs in the area – seven days before the prospect registers. This requirement would infringe on the privacy of every IBO whose name, address, and phone number was provided to prospects. It would also penalize the sponsor, who would be required to give his prospect contact information for 10 other IBOs, any of whom might be happy to register the prospect themselves. I propose to eliminate the requirement to provide 10 references. Having to give every prospect a list of all lawsuits, arbitrations, or other legal claims for the past 10 years involving Quixtar or its IBOs where the plaintiff alleged fraud, misrepresentation, or unfair trade practices – regardless of whether or not the accusation was true. Among other problems, this requirement would open up Quixtar and other legitimate companies to false accusations. Meanwhile, dishonest companies would simply ignore the rule. I propose that the requirement to disclose past litigation be eliminated. Having to make a different disclosure for every income claim.This would include any examples you might use during an opportunity presentation to illustrate how the Plan works. I propose if disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." The problem that I wanted to note is that you would be required to provide prospects with personal financial documents to back up ("substantiate") any income claim. IBOs 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. All the best, Lauren Ramage