|Received:||7/17/2006 12:52:39 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have read the proposed business opportunity rule. My opinion can be summed quite easily. You are killing a fly with a sledgehammer! The requirements you propose demonstrate that you have little understanding or concern for small business owners like myself. Let me give you some background. I have been associated with Amway and Quixtar as an independent business owner for about thirty years. I never built a "large" business organization, but have earned about the average amount that Quixtar currently publishes as the "average" income for an "active" Independent Business Owner (IBO). I occasionally show our business plan to interested individuals. This requirement you propose is impossible for me to meet. I do not know 10 business owners near where I live. Further, I cannot give out business owner's names and contact information if I cannot get their permission. Our business allows me to talk to anyone anywhere about how our business functions and the income opportunity. You are proposing that I must give detailed income information to potential business owners. As a Quixtar IBO, we have information that is required to be furnished to prospective IBOs. The information outlines the most recent average income figures. It also details how the business plan functions. Quixtar, as a company, expects all IBOs to follow the code of ethics and rules of conduct or face suspension of our business privileges. New IBOs can receive a refund of what it cost them to join the business. Your proposed rules are heaping onerous loads upon a small business owner like myself. Let me state one thing perfectly clearly right now. I have never achieved any of the higher "levels" in this business (platinum and higher). Nonetheless, I still choose to participate in this business opportunity. Why? Because it suits me and I like associating with the people in this business. However, your proposed rule would have me begging other IBOs to "use" their reference any time I might talk to a person about this business. Your rule "presumes" that I can get this information and have their permission to give it to others. This is not a light presumption! Some other business owner is under no obligation to allow my use of their reference information. If I am required to have 10 such references and I cannot get them, what am I to do? The FTC is proposing to kill a fly with a sledgehammer! Dishonest businesses will always violate rules. Honest businesses will be burdened with those same rules in an effort to remain within the rules. Dishonest businesses have continued to "pop up" even though the FTC has attempted to rule to stop them. Put away your proposed rule! There are already enough rules in existence to pursue dishonest promoters. Focus your efforts on pursuing businesses that evade and avoid your existing rules. Do not impose onerous and burdensome rules on businesses that have a history of cooperation with the FTC. This proposed rulemaking imposes a burden on businesses that are honest in approaching and presenting business opportunities to consumers. We already have a "buy back" rule wherein a "new" IBO can have their purchase money refunded in full for more than the 7 days the FTC proposes. I suggest the FTC withdraw this proposed rulemaking. The FTC should focus its effort on the unscrupulous operators.