|Received:||7/12/2006 11:10:26 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:R511993 We are an honest home-based business that will be very negatively impacted by R511993. It will ruin long-standing legitimate businesses in hopes of stopping fraudulent ones. It will take the competition by small business people out of the marketplace and replace it with a few big businesses in the home care, beauty and vitamin markets. It will take away the opportunity for many "little guys", young people, retired people and minorities. It will leave business only for wealthy people. We started our Amway/Quixtar business in 1972. We were both working at the time. I was into moving up the corporate ladder. We were an average young couple that needed everything – a decent car, house, furnishings, etc. We started to supplement our income. We liked the people who showed us the idea. They were total strangers. They never oversold or promised us anything. It was an opportunity for us. My employment became very difficult and Amway/Quixtar provided security against job loss but also towards retirement. Today we own our own home, Amway/Quixtar is our only income, our jobs went away from us and we have paid for college education for our daughter. We have hundreds of friends because of the business. We know their families; they come from all walks of life. We’ve been encouraged by many and we believe we’ve encouraged many. In 34 years in the business, we’ve never had a rule violation or complaint in our business. Concerning some aspects of the proposal: 7-Day waiting period. We disagree. Quixtar does not need this because we give money back guarantee. Registration is only $51.50. If prospects order product or later sales aids might move it $200. All money back guarantee. Sponsoring percents will go way down because in 7 days people lose interest. No sales business could operate with this rule. When we show plans we show Quixtar Registration Forms and attach the SA4400 Form. We show that both forms show average action IBO gross income at $115. This is a very easy business for someone to quit. All they have to do is do nothing. In addition, they can get their money back. We personally do not do any advertising through the media. We are startled by the claims made on newspapers, radio, TV about income in home-based business opportunities---especially real estate. Provide a litigation list. We totally disagree with this. Eliminate this. Much of the litigation is Quixtar taking action against those exceptions who are breaking laws and rules and misusing the Quixtar opportunity. Our personal experience has been that Quixtar Rules Department bends over backwards to do things right, by the law. Why penalize the innocent many because of the bad actions of the few? Does Wal-Mart have to post this in their stores? Do stockbrokers, doctors, lawyers, insurance people, stores, do this? NO. Our business is much harder for us today because of false accusations about Quixtar on the Internet. Can the FTC regulate what is said on the Internet that people have to be responsible for their accusations? Competitors and dishonest individuals can and are damaging honest, hard working people. We see many companies suffering. We have prospects and IBO’s that are interested in our business and like us and then go on the Internet, get discouraged and do not do the business. The largest business, like Quixtar, will tend to have the most “bad people” simply because it has the most people. Free speech should not mean guilty until proven innocent. Concerning a different disclosure for every income and providing prospects with personal financial backup. We strongly disagree. Please do not require this. The average IBO income we show is $115/month staple. The cost of the business is low – about the price of good shoes and requires no ongoing obligations, payments or whatever. It cost nothing for people to quit. They just do nothing. These proposals appear to be more large investments. Provide prospects with 10 references and verification of our income. Totally wrong. I do not want my personal information out all over. No other sales people are required to this. This is a real problem for privacy and identity theft. Our suggestions: Can the FTC make new, startup home base business opportunities register and go through a “certification” process? Identify the bad guys are and the good guys are and treat them accordingly. Do not saddle everyone with rules that will destroy their business. Other businesses such as real estate sales, stock sales, insurance, car sales, etc. do not have to do any of the items proposed by you in this proposal. Please do not discriminate against home-based businesses.