|Received:||7/17/2006 12:08:31 PM|
|Organization:||The Murdock Group|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I joined Amway/Quixtar the 2nd time in Nov. 1979 and achieved Gold Direct status in March of 1982. My check was $4,500 for the month of March--nearly double my professional salary that took 17 years of education plus 7 years of experience to earn! I was a single dad with a 6 and an 8 yr. old child, CEO of a charity and also serving on 18 boards/committees while dating in my spare time. If I had not built my business to the level mentioned, I would have lost my home. I had a balloon mortage that jumped from $279/mo. to $853/mo. I could not qualify for our home on my salary alone! I didn't achieve the same income on the prior enrollment in the 60's. My goals were different. It was not a factor of the viability of the business opportunity. I used it the first time to pay my way through college and terminated to join the Peace Corps. I didn't see it as a career option. It was the exposure to sound business practices, mentorship and positive input received from the Amway/Quixtar business that allowed me to move professionally from a small agency to one of the largest in the US where I also became President of the Large Agency Executives Council (International) in 1992. I do not share this information with my prospects normally. I do not want to set any false expectations. I am a high achiever in anything I do. It is unfair if they compare themselves to me. Very few make it to the top in anything. What I do share with them is what the "PERFORMANCE SCHEDULE" makes available plus a pledge of my personal time and support (which would cost them a fortune if I was paid as a consultant. It was $1,500/day in the '70's, but it is free to them.) Your broad axe proposal where a scapel--at best--is required reminds me of Henry David Theareau's remark, "We take a 1,000 blows at the branches of evil, for each one we take at the roots". If you implement your proposals, you will strangle an industry to death. Your approach is akin to requiring colleges and universities (and lending institutions) to disclose to all prospective students the income of all their graduates plus a disclosure of the non-refundable cost each student who quit or dropped out invested. In addition, how many found work in the field or currently work in the field they majored in in school. The education industry--using like standards--scams far more than the most renegade direct sales operation. Do you require colleges and universities to provide litigation lists? How about Social Security statistics on how many end up dependent or broke at age 65 with their education? Do you provide them a directory and invite them to contact current students? That invades a student's privacy. How idiotic! Someone getting started in our business will invest less before generating income than they would spend in application/registration fees just to get into a university! Plus it is refundable and tax deductable which their educational alternative may not be. Depending on their goals, that could range from $50 to $500. We provide at least one opportunity a month for prospects/IBOs to meet and discuss the opportunity with others. This schedule is published and distributed to them. Our business has some built in safegurards. ♦Because of MY cost of time for mentoring, training and development to help a prospect become a successful Independent Business Owner, I cannot afford to misrepresent the business. ♦These are volunteers. If they are lied to, they are gone along with my investment! ♦They get a written statement of the program, and the "averages". The document is SA-4400. ♦If anything, we are compelled by Quixtar to distort the facts by UNDERSTATEMENT. This is a retail business. Would you require a sign by every cash register requiring a 7 day hold to study the purchase along with a referral to Consumer Reports? You're creating not solving problems. Besides, the Internet provides enough skepticism to make any buyer beware.