|Received:||7/11/2006 11:41:37 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:1) A 7 Day waiting period is unrealistic, why not just require that ALL registration money be refunded to a prospect if at anytime within 90 days they request it back. No questions asked. This will not punish existing reputible companies and would hit bad companies where it hurts...in thier pocketbook. 2) Providing a list of references seems like a good idea on the surface, but I have had alot of problems with people from other teams stealing my prospects. After I present my opportunity and do all the work, they happen to run across someone from another team and they guy says, you should get in with me, not them, you'll grow faster on our team than you would on his. Then they register MY new prospect after I did all the leg work. If I had to provide a list of other people in the area who are doing what I am doing, there is no question it would create a devestating situation of infighting and prospect stealing. I already provide access for the new prospect to my sponsor and other active members of my upline support team. 3) A litigation list seems like a silly idea. If I was buying a McDonalds franchise, would I need to see a list of every lawsuit that happened against McDonalds and every other franchisee and all their employees? If this rule is established, the company should at least be allowed to respond or reply regarding the lawsuit in the margins of the document so that both sides of the story are represented. It should also be noted the RESULTS of the lawsuit, i.e. this lawsuit was found to be frivilious. This lawsuit was settled, etc. 4) Earnings disclosures are a very important aspect of our business and industry. It should be noted that it is only fair to the prospect if they recieve fair disclosures on incomes. It is not realistic for the average person to expect to make NET $5000 a month after being in a business for 30 days. Ads that I see that claim $100,000+ a year for doing nothing infuriate me. It makes the whole industry look cheap. We should raise the bar on income claims. We should talk about what the AVERAGE person who has been ACTIVE in the business makes. From my experience the average person gets two rejections and quits. It wouldn't be fair to count them in the averages if they don't do anything the rest of the year until their membership is up for renewal. If you're presenting that someone will make $100,000 in 2-5 years, you should also report how many people have actually done that. In fact, a better metric would be to report ON AVERAGE how many presentations a person would have to do to hit certain income levels. Every reputable company should know their averages. For example, on average 10 customer presentations results in 5 sales. 10 opportunity presentations results in 2 new business owners and 3 customers. So, if you want to make $500 a month, you should expect to make X number of presentations. 5) Should I be required to report my income to prospects? Good question. It would be good for everyone to "get naked" financially about what they make in this business to their prospects, but it does seem somewhat unfair to be required to do so. Let's say I've been only doing 1 presentation a week for 5 years and I'm required to show the prospect my checks for $60 a month. Not too exciting. But it is realistic for only working 1 hour a week. What is a brand new person who has only been in the business for 10 days supposed to disclose? Do you only have to disclose your bonus checks, or do you also disclose your retail markup on product sales which the company would have little way of keeping track of. What if a superstar discloses he makes $5,000 a month after 30 days and it's true! Is it fair to a brand new person who is NOT a superstar to expect to make $5,000 next month? Again, I think it's more fair and realistic for an average prospect to be presented with average results of the average person involved in the opportunity.