Comment Number: 522418-09199
Received: 7/14/2006 2:43:51 AM
Organization: MB Communications
Commenter: Matthew Baron
State: IL
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing to express my strong objection to some of the FTC's proposed rules for U.S. business opportunities. Along with my wife, I have been a Quixtar IBO (Independent Business Owners) since the inception of the business model in 1999. It has been one of the most positive experiences in our life, helping provide us with outstanding mentorship as well as a supplemental income that has enabled us to have more options in our life, such as being full-time parents to our 3-year-old twin children. While I understand that the FTC wants to have the ability to weed out and eliminate scams in the marketplace, some of the proposed rules would have the negative effect of placing undue burdens on legitimate businesses such as those affiliated with Quixtar. There are sufficient provisions already in place to ensure that people are treated in an ethical, fair manner. With my enterprise, I am careful about whom I invite into business. After all, I'm investing my time and money into helping them get their business started and profitable. As a result, I frequently decline to extend the business opportunity to individuals. However, we've had three occasions when someone wanted to undo their IBOship a few weeks after joining our business. I have always gladly obliged them, even taking the time to prepare paperwork to expedite the process. We make no money from signing up anyone, and integrity is a hallmark of how we do business. It's also one of the cornerstores of Quixtar, which is why we were drawn to the corporation. I have been a longtime journalist, and learned long ago that "if your mother tells you she loves you, check it out." It's a message I preach to anyone I consider adding as a business associate---I'd rather someone make an informed decision than a rash, emotional one. Again, the focus on any successful enterprise---when it is legitimate--is the long-term view, not the quick-buck mentality. Likewise, I urge the FTC to consider the long-term implications of their proposed rule changes and not focus on apparent "fixes" that would cause more harm than good. Specifically, I strongly recommend that the FTC: *Not require a 7-day waiting period before a prospect could register; *Not require IBO references be provided to prospects or disclosure of past litigation; *Not require financial records to be disclosed to prospects. I own a public relations/marketing/media consulting and training firm, and if those proposed requirements were in place for my day-to-day operations, it would be similarly burdensome. So those proposed changes, if implemented, would place an onerous burden on the operation of my business. It would also set an unwarranted tone of "guilty until proven innocent" suspicion and distrust that brings to mind the shameful fear-mongering legacy of the Joseph McCarthy Era. Thank you for considering my remarks as you proceed in your deliberations, and thank you for doing all you can to ensure that fair, honest and ethical businesses enjoy a level playing field while you rightfully target the elimination of predatory, dishonest and corrupt businesses. If I am needed to clarify any comments, I can be reached at