| Comment Number: | 522418-09082 |
| Received: | 7/13/2006 10:05:58 PM |
| Organization: | Quixtar |
| Commenter: | Ed Knickman |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife and began an Amway business in 1981 while we were living in Miami. We have recently "retired" from active involvement from Quixtar/Amway after 25 years of work. Amway/Quixtar has fully deliverd on it's promises and it's reputation and pricipaled leadership is to be admired throughout the business world. Your proposed rule regarding "business opportunity" presentations and recruiting has merit in some areas, but goes too far in placing unrealistic burdens one people who are attempting to build a legitimate business. I agree with the requirement for offering a clear, easily understood compensation program, emphasising the work required as well as the income that can be derived. I agree that there should be a "cooling off" period of no more than three days for people to cancel and recive a full refund of all monies. Furthermore, there should be a reasonable return and refund period of perhaps 90 days, on any product or demonstration materials purchased. I disagree with any delayed registration process which would signicantly add to the costs and delays to those trying to build a valid business. I disagree with the requirement to disclose the names of "local" references, as this is a violation of business owner's privacy. Additionally, no other seller of any reputable product or service is required to provide such information. And last, I disagre with the need to give full disclosure of any pending litigation against The Business when presenting the opportunity to a prospect. First of all, I have no way of knowing this information without doing a full search of all public records. Can you imagine a Ford Motor Company salesman being required to give a list of all law suits filed against Ford or Jauguar? This is a ridiculous suggestion. If people are really that interested, they can search the public records as part of their due diligence process, before they make a decision to proceed. There is an expression which says, "don't throw the baby out with the wash water". Quixtar/Amway has had almost fifty years of success around the world. It has brought hope and opportunity to thousands of people like me, who understand that success always comes at a price. And for those like me who are willing to do enough of the right things, with a good and honest attitude, for a long enough period of time, they will have a better chance for success and security here than anything that I have found in my 67 years of living and 50 years of work experience. Best Regards, W. Edward Knickman III Clermont, Florida