| Comment Number: | 522418-08184 |
| Received: | 7/12/2006 1:32:05 PM |
| Organization: | |
| Commenter: | Oded Eliav |
| State: | VA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Wanted to comment on a few issues regarding the proposed new ruling. Let me start by saying that I've been an IBO with Quixtar for several years and plan to continue building my business legally, ethically and morally as I've been doing so far. My biggest concern with seeing your proposal is that it will have a SIGNIFICANT impact on our ability to develop our business, while other so-called opportunities will continue to ignore these new rules just as they ignore other rules and laws. Specific concerns regarding the new proposed rules: 1. The 7 day wait - Quite often prospects are at long distance that requires either flying or long drives. Having to come back after 7 days just to register them could become very costly, especially in view of the 100% money back guarantee that we offer all new IBO's for 180 days ! 2. References - By providing new prospects with names and numbers of other IBO in the area, you are opening a huge opportunity for 'stealing' prospects. In addition, why should I or anybody agree to freely distribute our names and phone numbers to hundreds of cross-line prospects? If a prospect in the future gets upset about anything, he now has at least 10 phone numbers of people he can harass. 3. Personal Financial Documents: This will make it impossible for brand new IBO to sponsor anybody, while existing successful IBO will be able to continue and grow their business since they have proof of their income. This rule will convert all legit businesses into real PYRAMID SCHEMS! 4. Disclosure of lawsuits etc. - Why legitimize any frivolous accusations? If someone filed a claim last week that I am not aware of - will I be breaking the law if I don’t disclose it to new prospects? Do I know have to hire lawyers to keep track and join me every time I do a presentation of the business plan? I think your intentions are good, and there is room for new regulations to reduce the number of illegal 'opportunities'. However, some of the regulations proposed here will cripple legal and honest business that cooperate with the FTC, while allow others to grow even faster. I would suggest that instead of imposing these rules, the FTC provide on their web-sites and other ways a list of approved companies and compensation plans. We will be more the HAPPY to point prospects to that list and/or any other bulletins published by the FTC that will help prospects make an intelligent decision. Thanks Oded Eliav