| Comment Number: | 522418-12041 |
| Received: | 7/17/2006 5:53:14 PM |
| Organization: | IDABIZ |
| Commenter: | Margaret Flood |
| State: | IL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
As an independent busines owner powered by Quixtar, I am submitting comments in reference to the proposal under review regarding "The Business Opportunity Rule" as I have several concerns regarding the stringent and intrusive nature of such proposed changes. While I appreciate the need to regulate and prevent fraud in what is now a prolific business model, I feel the recommended changes requiring a seven day waiting period, litigation lists, 10 references, specific earning disclosures and financial substantiation are repetitive of already existing practices I employ (quoting average incomes of active IBO's already documented with the FTC oversight on written presentation materials), counterproductive to profit potential for IBO's and irrelevant in the case of citing ALLEGED poor practice. Requiring specific earnings discosure with financial substantiation is intrusive to people's privacy and may be a disincentive to become an entrepeneur because they may feel their success or lack thereof is no one else's busines to know. As an alternative solution, I recommend that the FTC universally require each and every business of this type to submit "average income levels of ACTIVE business owners" and to further require these businesses to provide each prospect (along with a signature sheet documenting they received this FTC required document) a "Business Integrity Sheet" which will provide a list of the websites where they can research the health and integrity of its business practices, such as the FTC website, the Better Business Bureau etc. This "Business Integrity Sheet" should also include the website(s) where past RESOLVED litigation can be investigated and evaluated. (encouraging review of "allegations" opens the field for inappropriate negative attack of each others enterprise) Should a disgruntled or potential fraud victim file a complaint, the IBO can produce the signature sheet indicating they were provided with the FTC required "Business Integrity Sheet" and educated about unbiased resources where they could research the business opportunity and also be encouraged to look at them. On this same FTC required form ("Business Integrity Sheet"), the other appropriate proposed recommendations can be listed and encouraged (i.e., request references of other IBO's on their team, ask for FTC documented average incomes, etc.) I believe this would address the concerns of the FTC in protecting vitims of fraud. We are fortunate to be affiliated with Quixtar as the business practices we employ are of high integrity per our charter. Therefore, we have a positive perspective on how to do things. Perhaps the FTC whould implement good practice standards through a required documentation process that each prospect considering direct selling will have documentation of to keep, rather than leaving it to individuals to carry out the proposed rules and be held accountable only when a violation is reported. Several people who look at one direct selling opportunity will look at others at some point and if they see the same FTC Business Integrity Sheet as described above (with signature documentation by the prospect that they received it) provided universally by all direct selling companies as a requirement, it levels the playing field, educates consumers about doing due diligence before taking on a business opportunity while limiting the destructive practices entrepreneurs could employ towards each other by violating privacy or making false allegations to undermine a competing company. I appreciate your review of these comments and I appreciate your interest in protecting all consumers. Respectfully Submitted- Margaret M Flood IBO # 3620125