Comment Number: 522418-10583
Received: 7/16/2006 6:07:54 PM
Organization:
Commenter: George Wehrman
State: NH
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am the owner of an independent business powered by Quixtar and am totally supportive of reasonable rules to prevent fraud and false claims. However, I find several of the proposed rules troubling as follows: 1. Re: 7 day waiting period. We have a money back guarantee for the small investment involved - the size of grocery bill. Perhaps large required investments without guarantees should have a waiting period. Eliminate the waiting period for those with a guarantee and/or under a certain threshold required investment. 2. Re: List of references. We introduce new people to other members of our business team as soon as possible - the same people we would list as references. We also supply other reference material. A list that the prospect would call or visit at their convenience would infringe on people's privacy and be akin to inviting competitors to use my prospect list! Eliminate the requirement to provide a list of references. 3. Re: List of legal issues. Onerous to say the least. Due diligence is justified - with some regard to the risk involved. The internet provides a wealth of information for those who choose to investigate to whatever degree they feel is required. Eliminate the requirement to disclose past litigation. 4. Re: Income disclosures, Income claims. Quixtar provides audited average monthly/annual gross income figures for various achievement levels and bonus types - this is more than adequate. If an individual chooses to make personal income claims with substantiation that's their right - it is not proper for it to be mandated. Thank you for providing the opportunity for comment and for continuing interest in fair and honest business practices. George Wehrman