|Received:||7/15/2006 11:15:28 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My husband and I became Amway distributors in January of 1991 and in September of 1999 elected to become Quixtar members. We reached a level in 1992 where I was able to quit my job and stay home to raise my children. In 1993 my husband was also able to quit working. The business gave us the opportunity to homeschool our children and also to have more children. We probably averaged about $60,000 to $70,000 per year in income from our Amway/Quixtar business. We never felt misinformed about the opportunity. We have had 100s of people in our downline and most have been satisfied with the information they were provided relating to income potential. We have always been very careful to make sure prospects know that it takes a consistant work effort to build the business to a level where they are making thousands of dollars per month. We do have many women in our downline who have been able to quit their jobs and stay home with their children because of the extra income they have made in the business. Many of those people make hundreds per month, not thousands, but it makes all the difference in the world to them. We are also in a line of sponsorship that really teaches about getting debt free and this has been a big asset in helping people to have a better, less stressful lifestyle. When we sign a person up in the business they typically spend $100 to $150. The difference is whether or not they plan to build a big business where they need tools or if they just want a small business where they some products to get started. If a downline in our business quit they can return everything they bought for a refund. We have seen Quixtar refund them the registration fee also. We have never had a downline who quit and didn't get a full refund if they requested one. A seven-day waiting period would be very bad for building our business because people change their minds in two or three days, let alone seven. It seems very out of line that we would need to give a person 7 days to think about spending $100 to $150 that they could get refunded in full when the same person could spend thousands on a car or furniture, etc. without any waiting period. I think a 100 percent refund guarantee for 30 days or something like that would be much more in line with other purchases. We personally do that anyway so it wouldn't affect our business in a bad way. If you could see all the moms who have been able to stay home and all of the couples who haven't gotten divorced and all of the people who have straightened out their lives because of the business and you look back at how many of those would have changed their mind in 7 days, you would see the damage that you would be doing with a rule like that. Make it a money back guarrantee instead. I think that the same thing applies to the references and litigation list. We don't get any information about places that we buy cars and furniture from and that costs a lot more. If there is a money back guarrantee then it puts the burden on the upline to help those people so that they want to continue with the business. We know of people who didn't do well in the business but we did - just like every other business in the world. This is a business that can work for many people and by putting out too many disclosures and warnings you would be scaring people for potentially no good reason. As far as earings disclosures and financial substantiation goes, I think it is important that other multi-levels have to do the same thing we have always had to do and show the real averages - then we will look good by comparison. I don't think you need to go any further than that. Again, there is no other business that needs to give nearly as much up front information. Just do something simple that is a standard for all direct sellers. This business has been a blessing for our family and I would like to see many more families blessed by it also.