|Received:||7/13/2006 12:26:37 PM|
|Organization:||Quixtar Independent Business Owner|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:The proposed business rule currently being considered will drastically effect the ability of independent business owners (IBO's) such as myself to conduct business. Although the goal of this rule is to prevent unscrupulous companies from taking advantage of prospective individuals, it seems there is little that can be done to actually enforce this rule. These companies will continue to defraud prospects while legitimate companies suffer the consequences of these rules. The waiting period suggested in the rules should not apply to those companies who offer a full refund to consumers who are not satisfied. Furthermore, disclosure of a list of references will undermine the ability of IBO's to succeed in the business. Disclosure of prior litigation will only open up the business to false accusations based on previous frivolous claims. Finally, while all IBO's should maintain substantiation for any earnings claims, disclosure should only be required in the event of an investigation by the FTC or other governmental entities.