|Received:||7/15/2006 8:05:23 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have operated an E-commerce business powered by Quixtar since Quixtar's inception in 1999 and are at a level known as "Founders Platinum" with hundreds of people in our organization. Every group in anything has a few "bad apples," but the integrity of the independent business owners that we have been associated with is of a higher caliber than any other group of people that we have known. For those errant few, Quixtar has an excellent internal correction program. We have always stated up front that this is not a "something for nothing" thing and will require work over time. Some people join quickly, while others wait for a while. That is their choice and that is fine with us. But to require that people could not begin for a certain number of days would be detrimental to our business and possibly to the prospect who may, because of required hesitation, opt out of the best opportunity he or she might ever have. As far as we know, no other business has a required delay before doing business with the public. And no other business has to financially disclose all incomes to anyone other than the IRS. Not all hardware stores make the same money, just as no two Quixtar powered businesses make the same income. As they grow out, all have a different structure and income. We explain our business with a model to show how it works, and explain how theirs will be different and their income will be smaller or larger. We are very strongly against the requirement of providing 10 local people to contact. Does Sears or any other other business have this requirement? And I hope we are not one of the ten people to contact. I am busy enough without the telephone ringing continuously for recommendations. I believe people should do due diligence (A Google search is not due diligence.) Perhaps, the FTC should educate the public how to perform due diligence. In closing, I think your intentions are honorable. People acting unscrupulously have no business being in any business model. However, my instincts tell me that laws probably already exist to prevent most of this type of negative behavior but are just not enforced. Some years ago, I heard the Ex-Attorney General of Vermont say that only two MLM businesses in VT. were totally legal (ours being one of them). When asked why he didn't do something about the non-compliers, he stated that there wasn't enough money in the budget, and he wouldn't do anything until receiving several complaints. I would hope that, in you honorable attempt to protect the public, you do not create rules so restrictive that the industry dies. "The operation was a success, but the patient died," is rarely a desired outcome.