| Comment Number: | 522418-12579 |
| Received: | 7/17/2006 11:00:37 PM |
| Organization: | Crowe Dreambuilders |
| Commenter: | Nicholas Schwartz |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife and I have been Independent Business Owners (IBO’s) supported by Quixtar for over three years. We have had an awesome experience so far and expect that to continue. If the rule that has been proposed goes into effect it would greatly change the way we operate our business. While I agree that consumers should be able to access information to make an educated decision on any business opportunity, I feel that the proposed rule is too strict and would over complicate our business procedures. Currently, the proposed rule would require a prospective IBO to receive a disclosure statement, as well as, contact information or references of ten other IBO’s in the area seven days prior to registering. There may be individuals that do get registered and then later decide that they no longer want to be affiliated with our business and should be allowed a reasonable way to cancel their business, but a seven day waiting period to get registered seems excessive. While I agree that requiring a disclosure statement with clear and simple to understand statistics would be a benefit to the perspective IBO, a seven-day time period to review such information seems extreme. In regard to the list of references that would need to be provided to the prospective IBO, this requirement seems strange, and goes beyond typical business practices in the US Free Enterprise System. This proposed rule would also require that a list of legal allegations against Quixtar and its IBO’s for the past ten years and require IBO’s to calculate and make disclosures for every income claim. In my opinion this would violate the privacy of IBO’s and their financial standing. We respect the attempt of the FTC to keep US business ethical and legal however, our goal is to empower individuals to become Independent Business Owners. There is a tremendous amount of information on our business that individuals can look up for themselves. At some point people need to be accountable for their own research and choices.