| Comment Number: | 522418-09894 |
| Received: | 7/15/2006 12:58:31 PM |
| Organization: | Pioneer Group (Quixtar) |
| Commenter: | J. Leonard Moreau Moreau |
| State: | NH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Gentlemen: Thank you for this opportunity to comment onproposed rule changes for MLMs I;ve been anIndependent Business owner affiliated with Quixtar for 9 years. In addition to earning income, I've had a chance to meet a number of wonderful, success-oriented people. Through the non-obligatory teaching system of audios, books and business development functions, I have been able toe xpand my personal horizons and grow as a person. It only costs about $120 to register, which includes products which can be used or sold, earning bonus points.. I offer the following observations: 1. I feell the 7-day waiting period would have a "chilling effect" on future prospects, making registration burdensome on them and their prospects as well as needlessly cumbersome, dulling enthusiasm as well. This would also expose them to negative comments by friends and negative blog sites which are spawned by many legitimately successful businesses. 2. As with blog sites, litigations, both real and frivolous, follow on the heels of success. Providing a list of such cases would leave the message: If you become part of this business, you're likely to get sued. The definition of "seller" in the proposed rule seems unclear. Does that include everybody with a busines affiliated with the parent company? 3. The proposed disclosure of personal income to a prospectI feel would be a violation ofprivacy, as well as misleading. A new IBO who had not received his first bonus check, or had received a small amount after his first month would leave the impression that this business does not work. Likewise, an IBO with a 7-digit income would produce unrealistic expectation, despite disclaimers. To those who labor under a "paycheck mentality", the idea of residual, exponential income potential has a hard time taking hold. In short, one person's income is not indicative of how much another person may earn. 4. I find that having to provide a list of ten IBO "references" presents problems: A prospect, having had to wait 7 days to register, now has to come up with 10 references from people he has never met -- a "double whammy" before he even gets to start his business. If he is part of a group whose LOS is not in the immediate area, he would have to contact people from other groups. This would open the prospect to "crosslining" (receiving business information from those who do not have a vested interest in his success) or, les likely, being recruited into someone else's organization. While the people I've met in this business are of very high integrity, I don't know everyone.. Thank you for your attentionto these comments. Sincerely, Leonard Moreau