| Comment Number: | 522418-11994 |
| Received: | 7/17/2006 5:23:29 PM |
| Organization: | J. Blakely Enterprises |
| Commenter: | Joseph E Blakely Sr |
| State: | IL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
We are Independent Business Owners since August of 2005. This is not the first multi-level marketing business that we have tried, but it has been the most rewarding financially, and we have attained personal inward growth through mentoring, association and a wonderful Brit World Wide Training System. When we registered we were well informed about what we had to do to enable us to build a viable ongoing business through hard work, that would provide residual income for our future and that of our family. Anyone that we prospect we make certain that they are fully aware of how the system works, and the short and long term benefits.They are informed that this is not a get rich quick plan and that their success is dependent upon their work ethics, the amount of time and effort that is put into their business. The registration fee is nominal, the fee and the optional product fee is usually less than $165. They can get their money back if they are not completely satisfied. Some of the FTC proposed Rules would adversely affect our business as noted below. 1. The proposed 7 day waiting period for prospects after receiving their disclosure, before they could register should be eliminated. Prospects can get their money refunded if they are not satisfied as stated in our Business Reference Guide. A 7 day wait would also delay them getting started prospecting and selling to their friends, relatives and others 2. The requirement to provide prospects with the name, address, phone # of 10 other IBO's in the area, seven days before the prospect registers, violates the basic privacy of individuals. This would violate the privacy of all individuals involved and would penalize the sponsor who would be required to give up the information because then the prospect could possibly register with any one of the persons names given. At our Open meetings there is ample opportunity for all prospects to meet and talk with all the IBO' s who are present. At that time questions can be asked and answered and there is no violation of privacy by a third party. 3.The requirement to provide prospects with a litigation list covering all lawsuits, arbitrations and other legal claims for the past 10 years involving Quixtar and its IBO's where the plaintiff allegeds fraud, misrepresentation, or unfair trade practices - regardless of whether or not the accusation was true shoud be eliminated. This presents an unfair burden on the IBO and to the industry to keep track of and provide this information to all prospects. The information if provided could be used by others for unfavorable, unfair and false accusations. 4. The requirement for specific earnings disclosures should be eliminated. The only requirement should be to provide an average monthly gross income disclosures for active IBO's such as Quixtar is currently providing prospects both during presentations and on our website. 5. The requirement that IBO's must provide prospects with personal financial documents to back up any income claims shoud be eliminated. This clearly violates the privacy of IBO's to have to show or provide personal financial documents to prospects. IBO's should have the back-up for any claims but should not have to disclose it except for state agencies requiring it or to the FTC. Thank you for the opportunity to express our points of view and concerns and hope that you will take them into consideration when making the rules. Our business is transparent and we deal honestly with our propsects and we just need the opportunity to continue to work at our business.