|Received:||7/16/2006 9:11:55 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am a QUIXTAR IBO, and have been a registered IBO either with Amway or with QUIXTAR for eight years. My progress has been slow, but the slowness has been due to my own efforts and not from deficiencies in the infrastructure of the business as it has been made available for my use. The recordkeeping and reporting requirements from the proposed FTC rule as to local references, list of lawsuits, and all substantiation of income claims would be substantial for a very large corporation, let alone an individual searching for his shot at success. The support from the corporation, the quality of the products and training offered to IBO's, and the excellent disclaimer contained in form SA-4400 (which must be made available to every prospect prior to registration) take significant steps to ensure that a prospect considering registration in a QUIXTAR business is afforded all reasonable assurances that honest effort, applied consistently over weeks and months, will creat significant financial compensation. For an individual working from his house to have an honest chance for success, these existing protections are more than adequate to meet the spirit of the proposed rule. The administrative burden created by the proposed FTC rule would cause significant challenges for honest compliance with the rules, while scofflaws with no interest in compliance would pursue "business as usual" to the detriment of anyone looking for honest opportunities. In short, the target businesses would be less affected by the proposed rule than would honest entrepreneurs. I also question FTC's ability to monitor for compliance of such a rule; the burden for enforcement would be a significant dilution of efforts currently being focused on more significant challenges.