Comment Number: 522418-07385
Received: 7/10/2006 5:41:09 PM
Organization:
Commenter: Paula Schroeder
State: MA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

My husband and I have been involved with Quixtar/Amway since 1988. We are not making millions of dollars but this is not the fault of the business or its plan. I believe the reason for creating a 7-day waiting period is to help people when they have made an impulse purchase that they then regret. When prospected, we were given more than enough information to make an informed decision and we were excited to get started right away. We knew this was a safe decision because Quixtar offered a 100 % money-back guarantee if we were dissatisfied in any way. Waiting 7 days would only cause a slowing of enthusiasm that would then trickle down to any other prospects. Instead of a waiting period, requiring a money-back guarantee seems a better solution. This should eliminate the need for a waiting period by any legitimate business. With so much emphasis these days on privacy, I find it interesting that requiring 10 people to agree to allow their business information to be public to anyone but the appropriate government agencies to be outrageous. This also places individuals at risk who have worked so hard to obtain prospects and then allowing 10 other people the opportunity to woo them away. As for the list of lawsuits, imagine if everyone had to do this with their businesses, especially in this lawsuit-happy environment in which we live. All of this information is available to the general public online anyway and to actually be required to provide this information could make any business, no matter how legitimate, seem shady. Of course, shady businesses will simply ignore the rule in the first place and only legitimate, law-abiding companies like Quixtar would comply and lose business because of it. Requiring a different disclosure for each financial claim borders on absurd. When viewing any business plan for the first time, no matter how simple the program, it can be confusing. How much more confusing could it become with this rule. Providing clear and overall information at the end of the plan is more than sufficient like an average monthly income for active business owners. Providing my own income to "substantiate" claims is a serious privacy issue. This would require those just starting out to show how little they have made as well as those of us who have not built large businesses to explain our lack of hard work. This would be embarrassing and very non-productive. It would also be dangerous for those who are extremely successful in that a stranger would then be privy to information pertaining to their wealth and leave them open to identity theft, etc. Of course, all independent business owners should have their personal financial documents in order to pay taxes as well as for any other government or legal purpose. We appreciate that you wish to ensure that every prospect considering a business opportunity have all the information they need to make an educated decision. We and Quixtar applaud this goal. We are and have always been committed to providing prospects with complete and accurate information about our opportunity, so we fully support reasonable and responsible rules to help manage the expectations of prospects. Transparency and honesty serve as a solid foundation for any business. We share your support for this objective. We only ask that you consider these points when reviewing this proposal. As in the past, using Quixtar/Amway's business model as a model for how a legitimate business should run is a good idea. As with any business that involves people, there will always be problems, but I truly believe that Quixtar, along with other legitimate home-based or direct-selling businesses are the best chance for many people to make it in the business world. In your interest to remove fraudulent work-at-home schemes, pyramid schemes, and other "get-rich-quick" scams that try to disguise themselves as genuine business opportunities, you may be causing more problems than you will solve. Thank you.