| Comment Number: | 522418-08645 |
| Received: | 7/13/2006 8:14:19 AM |
| Organization: | Esterly Enterprises |
| Commenter: | Carolyn Esterly |
| State: | NC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern, My husband and I have been involved in the Amway/Quixtar business for over 15 years, and would like to express concern regarding several of the provisions of the proposed Business Opportunity Rule #R51193. During the first several years of our involvement, we worked very diligently, and always found that the compensation we received was accurate according to what had been promised. We and our associates sponsored hundreds of people in those early years. We were instructed, and we instructed our distributors, that the business was not a get rich quick opportunity, and we made certain to provide the corporate form SA-4400, which laid out the comp. plan and average income, etc. This was always stressed to us, and we passed that information along to our group. Members of our organization were clear how the money was made (through sale of and profit from products, and bonuses). We see the business as a great way to produce a source of income, work with like-minded individuals, and reach our goals. Several of the proposed provisions would seriously jeopardize our ability to be successful in a direct sales business. First, I ask that you eliminate the 7-day waiting period to sign-up, and instead offer a reasonable cancellation policy for folks who change their minds. The opportunity is just as good on day 1 as it is on day 7, however, the work I have done to contact and explain the business to a new person will be severly diminished if they have to wait-around for 7 days to get up and running. Second, I believe that requiring disclosure of 10-years past litigation is very unfair to those of us who run honest companies, with full-disclosure. It is not expected that large companies such as Wal-Mart or Hewlett-Packard hand potential employees disclosures of past litigation; it would be very unreasonable and detrimental to our company if this were a requirement. Those lawsuits do not apply to all distributors, and would place heavy doubt in the minds of our prospects. Third, I believe the rules should not require disclosure of financial records to prospects. In any opportunity comes some amount of risk; adults realize this. This business is no different. We have found that when we work the business, our income has been paid on time and in the amounts promised by our initial contract. Sincerely, Carolyn Esterly