|Received:||7/14/2006 12:19:29 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To Whom it may Concern, I, like you, am concerned about the scams in the direct sales business. We would like to see anyone have a fair shot at being a business owner, but also fair and reasonable return and refund policies. We also think it is important tohave standardized and industry-wide disclosures that are accurate and not slanted either toward understating or overstating incomes. However, sometimes in our zeal to protect the relatively small number of people who make bad choices to engage in or succumb to scams or sschemes, we overly restrict the rights of honest, law-abiding, hard working people. I believe there is some of that in your proposal. I do not think there is a need for a 7 day waiting period when there is a satisfaction guarantee and refund policy in place. In the case of Quixtar, there is a 6 month satisfaction guarantee that would refund 100% of start up cost. You can join Quixtar for around $55.00. There should be no disclosure of past litigation. Any big, successful company like Mary Kay or Avon or Quixtar have had some litigation simply because of their size and years in business. We all know that some of that is unfounded. The goal you have of stopping the new, untested, get-rich-quick schemes would not be accomplished by this. They would be too new to have legal challenges get through the system. Also, I believe that the most sued corporation in the country is Wal-Mart. Are you going to make them put a big sign up on all their stores warning the public that they get sued thousands of times a year? Also, there should be no required disclosure of financial records. Every individual business owner can have total control over how much money he makes by his balance of width, depth and gross sales. No one is limited by any other business, so the disclosure is not necessary. Thank you for your concern and desire to make the direct sales industry fair, affordable, and safe. May I suggest one area you didn't address here is to make all the new companies coming up get their compensation plan inspected before they start so that there is less illegal activity to begin with.