|Received:||7/17/2006 9:07:17 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am pleased to learn that the FTC is updating business rules. I believe updates will allow the government and businesses to better adapt to the market and protect the interests of consumers and business owners. I do have some concern over the present form of the proposed rules, however. First, it is entirely laudable to protect the investment of prospective business associates. I believe that should be done by requiring some reasonable refund policy. The proposed waiting period may have a damaging effect by forcibly limiting the growth of new business. Second, it is very good to quote standardized income claims, as that will provide reliable data for the prospective associate to make an informed decision. This data should not be based on personal financial records, however. Personal financial records should, rather, be safeguarded as they are confidential. Additionally, such disclosures may be a source of confusion if individuals are introduced to multiple persons who have achieved similarly but posess different incomes. Third, while it is good for prospective associates to meet current associates, it is potentially damaging to require a list of references as there is no protection of the efforts of the business owner who performed the work if one of the "references" should turn competitor. Also, there may be privacy issues if the prospective associates should misuse the reference data. Again, I believe these rule changes should be a positive development. Addressing these issues should help make it so. Thank you.