Comment Number: 522418-11936
Received: 7/17/2006 4:50:36 PM
Organization: Winters Marketing
Commenter: Doug Scyphers
State: WA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I have been an IBO with Quixtar from the beginning of the launch and the pre-launch of 1999. Prior to that I was an Amway Distributor since 1987. Today I have achieved a significant level in the business. I personally find the FTC proposals out of line and unnecesary. There are alternative means to curb fraudulent activities. The listed proposals of references, litigation, financial information, waiting period, and disclosures would all slow down the business or hinder new business or possibly eliminate business. Quixtar and Amway have always had a high code of ethics and morals and standards. Maybe the FTC should look at Quixtar's Rules of conduct and code of ethics and adopt some of those policies as law for governing a legitamate business. Better yet, ask the owners of successful companies in the industry to brain storm on how to best serve the interest of thier people and the public and still provide a basis for debunking frauds. Sincerely, Doug Scyphers