|Received:||7/17/2006 12:38:55 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an Independent Business Owner for 5 plus years and have met several of our goals through this business system. We have been able to blend it into our lifestyle and have enjoyed the serendipities of the business. The education system has been a real bonus for us. We have cultivated many close friends we would have never met if not for this business. I was given ample opportunity to investigate this business and give all my potential prospects the same consideration. I emphasize that this is NOT a get rich quick plan but one that requires hard work with no guarantees of success. I encourage them to do their own due diligence by contacting the BBB, the Direct Selling Association and/or Business 2.0 before committing to this business opportunity. Prospects are not encouraged to register on the first presentation but rather we prefer they consider all aspects for 24-48 hours at which time we will answer any questions they have. A waiting period of 7 days would jeopardize a new client in starting their business. It also would deminish the volume of business to business income. Imposing a 7 day waiting period would be adverse to our business as well as that of all our potential clients and should NOT be adopted. Requiring business references of other IBOs in the area would be an invasion of privacy and could adversely affect my business by opening the opportunity for another business to capture the results of my labor. All clients are encouraged to attend weekly meetings of the team where they will meet other successful business owners without my providing the business owner's personal information. Initial registration fee and product pack, if ordered, range from $60 - $150, all of which is 100% refundable for 6 months. All products are fully guaranteed with postage paid return provided. Providing a list of litigation is just absurd! This would open all legitimate businesses to frivolous lawsuits and do nothing to protect potential business owners. Dishonest businesses would just ignore the rule. Do brick and mortar stores have to provide their customers with a list of litigations before a product is sold? This rule should NOT be adopted. Earnings disclosures are part of our business plan proposal. A simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs is presented during the business plan. This proposal should NOT be adopted. Providing written documentation of my income to all potential prospects is completely unwarranted. We do provide them with the pin level we have accomplished and the general level of income this could provide. Specifics above this is just not necessary and this proposal should NOT be adopted. I appreciate the FTC trying to strengthen the field for direct selling opportunities but hope the rules that are implemented will be well thought out and not further hinder our legitimate business.