Comment Number: 522418-07533
Received: 7/11/2006 1:41:15 AM
Organization: Krotoski&Associates
Commenter: Nicole Krotoski
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I support open and honest communication in regards to business ventures and opportunities. However, I do not support over burdensome rules which have greater restrictions than traditional businesses. 1) Eliminate the waiting period for opportunities that offer unconditional money back guarantees if not satisfied with opportunity. Standard businesses and investments do not require a seven day waiting period for transaction consumation. 2) Eliminate the requirement to provide 10 references...it would be in violation of privacy rights of others. Certainly a prospective owner could request them similar to dealing with prospective service/business people now and then provide them with the reference's permission. But a requirement is going too far. 3) Eliminate the requirement to disclose past litigation and alleged fraud. First, no traditional business is "required" to do so when dealing with potential investor/buyers. Second, allegations can be untrue and shouldn't be required to be disclosed. Third, it would be difficult for any prospective business owner to know all the potential cases at any one point in time all over the U.S. 4) If income disclosure's are required, a standardized easily understood measure would be prefered. 5) Income claims can be made from a standardized example with perhaps caveats of the income claim is an example and actual results will most likely differ than the example.