|Received:||7/17/2006 8:41:25 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I believe that the new rules need to apply to any problems that have been brought to the attention of the FTC. But I also believe that companies that have been in existance for a long period of time (over 10 years) without major complaints should be grandfathered in at the rules they started with. To require a seven day wait period after a prospect receives a disclosure document and a list of references in the area is sometimes prohibited. Sometimes we are hours or even days from the prospect and would require a return visit for a sign up fee under $100. Also it would limit the area you could sign up prospects because of the list of references in the area. The requirement of listing all legal allegations against the company should be like asking McDonalds or any other fast food company to list all their legal allegations before selling a francise. To require IBOs to calculate and substantiate for every income claim would be a burden on both the IBO and the prospect in the amount of sheets of paper to cover all the different aspects of the business. There should be a simple and standardized income disclosure form for all companies. Also there should be a reasonable standard cancellation policy for all companies this would take care of seven day waiting period if the a signature was required for having received the disclosure document before signing up. Both the income and cancellation policy should be easy for a prospect to understand and easily inforceable by the FTC with out costing additional fees. Because of the low start up cost, for a Quixtar IBO there should not be required that the IBO disclose personal financial records to prospects.