| Comment Number: | 522418-07409 |
| Received: | 7/10/2006 7:23:18 PM |
| Organization: | |
| Commenter: | James Parda |
| State: | CT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
We have owned an independent family business for 26 years. We have been able to attain a goal of positive cash flow from this business. The friendship and mentorship have been invaluable. Upon registration we received more than enough information to make an informed decision and supply anyone whom we have registered with the same. We attempt to get all questions that a candidate asks answered. All prospects are given the information that as IBO's we cannot and will not guarantee any level of success. They are made aware verbally and in print that they will be Independent Business Owners and that what they earn will depend on their ability to learn successful business methods and work hard. If a prospect has to wait seven days before registering, it would have a negative affect on all business. It would discriminate against those people who make a decision and want to get started quickly and begin earning income. The ability to police a seven day waiting period would be impossible. The proposal to require a litigation list is beyond the realm of independent business owners. For example, is any contractor, store owner or franchise owner required to provide a litigation list for all same industry owners across the country? Also, the proposal that IBOs would need to make specific earning disclosures is an invasion of privacy. Today we follow the rules on conduct, provide a current SA4400 and make no exaggerated claims or guarantees of income potential. We have never provided prospects with personal financial substantiation. One's personal income is a private matter. We provide substantiated information to the US government for tax purposes. Very few IBO candidates have ever asked for those details as most people respect each others privacy. What one business might earn and spend, another business might earn and save and have little if any of a lavish lifestyle. In talking to an IBO candidate, the most important thing is honesty, sincerity and develop personal trust.