|Received:||7/17/2006 1:31:37 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Regarding the proposed Business Conduct Rule, I have significant concerns about its content. I have been in the workforce for over 40 years and self-employed for over 18 of them, and have owned an Amway/Quixtar business since 1988. That business is a part-time income and has helped me support our my family and church for more than a decade. During this time, I have never encountered ANYTHING unethical in the way the corporation conducts itself. Their buy-back rule and rules of conduct are always applied, and I have personally experienced them enforce those rules when inappropriate behavior occurred. I am also a graphic designer and writer and my husband is an author, playwright and musician. So we both have worked with many companies and institutions, so I speak from considerable experience in business when I say all businesses do better with speedy growth, quickly meeting the needs of their customers. This includes prospective Independent Business Owners, individuals who have a need to make a change. An arbitrary waiting period, when the investment is under $200 and there is a buyback rule in place, is simply unnecessary and unwarranted. It may be imperative if one is investing an lot of capital in a commercial venture such as a Subway or Wendy's, but it is overkill when one is buying a guaranteed registration pack, and some energy drinks, tea or coffee for their consumption! I would recommend eliminating waiting periods for Quixtar or any company where the person can get their money back. The proposal to require a list of ten references is totally unworkable. Not only are there the obvious privacy issues-I do not want my info given out to just anybody. Who knows whose hands that information could land in? Providing a list of lawsuits is also totally unworkable. Whose lawsuits? Quixtar's? Mine? Some individual in the line of sponsorship? Some other line of sponsorship? Some jerk who was already terminated by Quixtar? Devos? True? Untrue? Bogus? Harassment suits? False accusations? This should NOT be in the rule. If someone wanted that info they should be able to find it esily enough of the internet. Which in my opionion tends to be the bathroom wall of society I think disclosures are fine. For my entire career in this business we have used disclosure. We train all people to use the company-approved numbers and we are REQUIRED by Quixtar to provide income disclosures. All people are different however. And anyone who works with people knows that. So, what one does, does not mean the next one will do. He may do more, he may do less. The choice is up to the individual in a free society. If you want to use an average (like we ALREADY do in Quixtar) pattern it after Quixtar's. It must be simple and easy to understand. Our goal is to HELP the prospect make a good business decision, not confuse him. To require me to give out personal financial information to a prospect is also UNWORKABLE. Who would want to start a business that requires they give every prospective customer their financials; imagine how long your wait at Starbucks would be as well as the increased cost of a latte would be if financials had to be provided to each customer! I keep such info, but do not want to be required to disclose it willy-nilly. In a free market each individual decides for himself, through his work ethic, their level of success. Leave it like that if you want a Free Enterprise economy. In closing: hit the RIGHT TARGET.Not the WRONG one. To assume ALL business owners are liars and cheats is demeaning to millions of us in this industry. Use simple, common sense rules, and go after those whom you receive complaints against. Don't burden honest business owners. We will be the ones following the rules. THE CHEATERS WON'T ANYWAY!