| Comment Number: | 522418-09095 |
| Received: | 7/13/2006 10:25:39 PM |
| Organization: | QUIXTAR/ CHOICES |
| Commenter: | VIVIAN HOUGH |
| State: | MD |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My name is Vivian Hough, and I have been a practicing medical physician in the area for the last seven years. I have been an Independent Business Owner for a little over a year and would like to share my past experiences with the business and comments in reference to the new FTC proposal. First and foremost, I applaud the FTC efforts in protecting individuals by monitoring the practices of independent businesses. The fact that the FTC has regulated and approves of our business plan, gave me both the confidence as a prospect and the integrity of a business owner to become fully involved. This business provides more than just financial gain, but a opportunity for internal growth within a positive association. When I first registered I received the original literature packet that we current use along with several CD's of professionals in the field that I could related to in medicine. Today, we have a DVD of top CEO's and business owners provided this information along with a website of personal stories. Prospects have many resources to choose from when it comes to researching this opportunity and many of them we give directly to them. Once the initial business plan is shown a follow up appointment is mandatory to get started. Prospects have their questions answered and invest an initial $250 for registration, product samples, and business materials; all of which is completely money back guaranteed within 180 days. During the follow up interview, tit is made very clear to the prospect that the business requires work and time, and that financial gain is not an "overnight wonder". The new FTC proposal, however, contains many restrictions that will adversely affect my internet business. In reference to the seven day waiting period, this time delay not only is unnecessary given that the prospect has 180 days for a full refund, but hinders a prospect from getting their own business started. Also, given that we are paid on volume generated each month, a seven day waiting period will potentially delay each business owners abiltiy to complete their volume goals for the current month. I believe it is of great importance to be able for prospect to speak to other business owners prior to sponsorship. However, not everyone that has ever registered in a business chooses to be successful and complete their goals. Requirining prospects to speak with area IBO's exposes them to the risk of that prospect potentially signing on with that reference and exposes them to associates that may not have been successful to their own lack of effort. Privacy issues are of great importance simply because as an IBO, I may not want my personal information disclosed to just any prospect. I can see the benefit of contacting area Platinums and above (leaders who have reached a certain level) with their consent on the same team to avoid a conflict of interest. I believe specific earnings disclosures and financial substantiation is yet another violation of privacy. General averages are already provided by our literature packet. In short, I commend the efforts of the FTC in protecting prospects when viewing independent businesses, but I am not in favor of the specific provisions outlined that would penalize honest IBO's, like myself, and cripple our sponsoring efforts. I look forward to future revisions to follow. Sincerely yours, Vivian Hough, MD Independent Business Owner Powered by Quixtar