|Received:||7/11/2006 11:13:05 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:As a Quixtar Independent Business Owner (IBO) since its inception, I feel the FTC's proposed rule for business opportunities is too restrictive. Most legitimate business opportunities (including Quixtar) have rules governing business owners' actions. Quixtar's Code of Conduct is enough for any IBO to follow and for any prospect to understand the potential of the business model. Quixtar also has a money back guarantee for new IBOs to have the ability to cease their business without loosing any money. This makes the proposed 'waiting period' unneccessary. Several components of the proposed rule are cumbersome and will expose personal information about people and their businesses that are usually not public knowledge. In particular, the disclosure statements of personal financial claims and a list of 10 references proposed by the rule would be intrusive. Also, the unfair proposed requirement that alleged and unfounded legal issues be disclosed is useless since they are just that - unfounded and alleged. Disclosing past litigations is not needed as any legitimate business would amend their practices based on proven legal challanges. Finally, the proposed requirement to substantiate every income claim would make any business tough to describe and understand. No two businesses will every grow and develop the same, so having to substantiate every possible income claim is unrealistic. As with the Quixtar business model, it is just that - a model. During our explanation of the model, we stress that it is a model and individual businesses will be different. This approach seems more realistic and sensible. While I agree that fraudulent and unscrupulous businesses need to be eliminated, legal and above board businesses should not be made to suffer undue, intrusive, and unrealistic requirements.