Comment Number: 522418-08786
Received: 7/13/2006 1:35:06 PM
Organization:
Commenter: Karen Dercks
State: WI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

While I agree with the concept of regulating get rich quick schemes and fraudulent wok at home schemes, care should be taken not to adversely affect legitimate business opportunities. Reasonable business disclosures that are fair and help consumers make wise chioces are a good thing provided they are clear and simple. As an independent busines owner with Quixtar, I feel that a 7 day waiting period would hamper my business in that the increased regulation would make a prospect feel as if the business is too regulated and cumbersome to become involved in. I think the 3 day cooling off period on mortages is a good example of how this type of policy is circumvented and not used properly. The banks I use have had us sign it, post-dated and then they do the paperwork after that date. If we were to change our mind, they've also had us sign that paperwork and can institute it with a phone call. They simpy shred the unused paperwork. yWith a reasonable cancellation policy, uniformly aplied throughout the industry, ther would be no need for a 7 dat wait as there is no "buyers remorse" issue. I also feel that providing references would be cumbersome to those people being given as references to the point that their own ability to conduct business could be hampered by the incoming reference checks. Here too, references are only as good as the questions being asked by the person seeking the reference. Financial records are private information and should not be required to be disclosed. Furthermore, as the network marketing industry is based on performance, someone else's financial records are not an indication of what my finances will be unless I am performing on the exact same level. Furthermore, either of us can change our performance level at any time, causing the provided records to be inaccurate. Simple standardized income disclosures that apply to all direct sellers are a good alternative to the disclosure proposal. Sincerely, Karen Dercks