|Received:||7/16/2006 11:25:31 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Good morning, I am somewhat concerned about the proposed rule on direct sellers. To be required to inform potential clients of any and all litigation filed against quixtar or it's IBO's is a very unfair proposal. In my principal job as a Pharmacist that would be tantamount to being required to inform every potential customer of any and all law suits against myself and all other pharmaceutical providers, practitioners, wholesalers, manufacturors, retailers ect. Most of which I'm not even aware of. I as a pharmacist have never been involved in any litigation, but I can guarantee that there have been thousands of law suits filed. Further, I have recommended Pharmacy school to hundreds of students over my career, but no one has ever suggested that the students deciding to enter Pharmacy School wait to get started or meet 10 other area Pharmacist to be admitted. Upon their admittance some find that pharmacy school, engineering, law, medicine or any of the other disciplines that they may have had an interest in, was not what they want to make a career of. Visit any campus and see how many "major" changes take place over the average college career. For that matter, how many entire career changes occur over the expected work life of the typical college graduate. I have never given an earnings verification to anyone considering a career in pharmacy, I don't even give that data to my own State Board. It's not their business, nor should my earnings be considered in their decision. Some plumbers, mechanics, engineers, ect make more than others, some make less. Usually it depends on how much they put into their profession, and so too in direct selling. The more successful individual is usually the one that puts forth more effort or developes a better skill set. In direct selling, requiring a 7 day waiting period would handicap the Newest and weakest of the new IBO's, further they don't know 10 other IBO's in the area, nor are they aware of all possible litigation in the industry. I am aware that there is not one company in America doing 100 million dollars in business a year that is not involved in some kind of litigation on a daily basis. What litigation? Who knows. I support the concept of standardized income disclosures, and a reasonable cancellation period for new and prospective IBO's, but much of the proposed rule is an unfair burden to the industry and it's participants. Thank You!