|Received:||7/16/2006 9:42:52 PM|
|Organization:||IBO affiliated with Quixtar.com|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My concerns as an IBO are very similar to Quixtar and the IBOAI. According to all that I have read and studied and for as long as I have been an IBO the proposed "Business Opportunity Rule, R511993" seems to apply more burden on reasonable businesses then it helps to alleviate and discourage false businesses. Although some of the restrictions and regulations would be helpful, not all of the proposed rules would actually help promote legitimate businesses, such as mine. This rule ... • Prohibit prospects from registering as IBOs until seven days after they receive a disclosure document. • Require IBOs to give every prospect a list of “references” – which according to the reading of the law means contact information for 10 other IBOs in the area – seven days before registration. • List all legal allegations – lawsuits, etc.– against Quixtar and its IBOs from the past 10 years. • Require IBOs to calculate and make different disclosures for every income claim. • Require that every prospect receive “substantiation” for every income claim. My recommendations are very much in aggrement with those of Quixtar and the IBOAI. Yes it is necessary to support reasonable business practices and disclosures that are fair and that help consumers make more informed choices. Here is a proposed list of what would be fair and more reasonable if this rule were put into law. The "Business Opportunity Rule, R511993" should ... • Should require clear and simple, and if possible "standardized" income disclosures that apply to all direct sellers. • Should provide a reasonable cancellation policy and term. • Should not require a seven-day waiting period before a prospect could register. As in my business, I cannot find what this rule would help solve or alleviate, and in my experience would actually complicate issues and turn eventual IBO's or other type of clients away from doing business with reputable companies like ours. • Should not require IBO references be provided to prospects or disclosure of past litigation. When I shop at large grocery store chains it would seem ridiculous to require that store to hand every new person who walked in a list of disclosures of past litigation or references. So why would it be necessary to force an individual business owner to do that for every person they talk to, which would waste time, money, and economic resources. • Should not require financial records to be disclosed to prospects. Because my business is a person to person business, it is not economically feasible to have to create some sort of financial record that I must hand out to everybody I come in contact with. What would we solve by mandating that they be handed out to every face to face contact we have as an IBO?