Comment Number: 522418-07219
Received: 7/9/2006 10:38:32 PM
Organization: The Bedard Group -Quixtar IBO
Commenter: John Bedard
State: MN
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

It strikes me that the rules taken as whole would make a very simple business very complex and in effect "scare off" many of the people that I recruit. It almost seems like they and I would both need lawyers to review all registrations. I would suggest that the rules be similar to the rules that Quixtar follows following the FTC investigation of Amway some years ago. A standard statement of audited average earnings for all active regtistrants and for various award levels, a minimal profit at point of recruitment, and a 30 day period in which all registrants can get a full refund. Plus a buy back of any products purchased within 30 days of registering. Most of the people that I register pay less than $150 to register and most basically start by being wholesale consumers. Some then start building an active business later as they become more comfortable with the concept.They recieve from me a document showing the average income of all active IBOs. And many of them come to a meeting to meet other IBOs just prior to or immediately after registering. I feel that these rules would deter many of these from registering. Also, I have had a few who changed their mind within 30 days and received a full refund. It seems to me that these rules have a very good objective to weed out the frauds and scams. Unfortuneately, I feel that they will make it very difficult for those of use who are bulding a legitimate business. John R. Bedard