| Comment Number: | 522418-07562 |
| Received: | 7/11/2006 9:56:27 AM |
| Organization: | the upward ladder |
| Commenter: | kirk larson |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
As an IBO for the previous 10 years or so, I am very concerned about the proposed regulations. We work with the Worldwide Dream Builders and our goal is to help people suceed with whatever their goals are. As a teacher by training, I can attest there is not a better form of education, if the person chooses to use it, then the Worldwide Organization. However, being a teacher, I also understand human nature and many people do not take advantages of all we have to offer, and even, some just take a quick and judge it "not workable". But for those who have a vision and are willing to put forth the effort, the rewards can be enormous. To look at the specifics, the 7 day waiting period is unrealistic for human nature--it gives them a great deal of time to forget what they can achieve and focus on what they cannot achieve. I do support that there is a money back warranty if they do decide against it in a 7 day period of time. At worldwide, I believe the period is 180 days---- Requiring us to show income verification is again not a reasonable requirement. We can certainly show the potential one can make by moving products and the income they can make according to the products they move. Certainly, we advocate that training will only come from persons making more money in the business then perhaps the sponsor. Again, money is only made by selling products and NOT by signing us people--again, I would be oppose to getting paid for simply adding people. The FTC has approved the form we currently use, it indicates how much an average IBO earns----Similar to a univeristy education, if you go into teaching, they do not tell you how much you are going to earn but the ranges and exceptions are out there----- Providing litigation material--even cases not won, seems go go overboard. As with any company, there is litigation during this day and age--I'm sure even Mother Thersa had some claims against her---If the FTC brings litigation, maybe that would be valid disclosure but otherwise no matter how much we disclosed, at best, it would only be part of the story-- References are also a difficult thing to require because we are all independent business owners with different goals If I were to run for the senate, I would not expect 10 other senators to tell me what they make---if I wanted to pursue them I could but their goals may be different then mine. In the end, I think you would be wise to look at what Worldwide does and base your decisions on what we show and say--of course, if you are interested in the business, I would very much like to share this opportunity with you,