Business Opportunity Rule #522418-11045

Submission Number:
Initiative Name:
Business Opportunity Rule
To Whom It May Concern: My name is Cindy Dillingham, owner of Dillingham Enterprises; affiliated with I have been in business for over a year, and am seeing a good measure of success. Having read the proposal, I am in support of the position that every prospect looking to start their own business should have the information needed to make an informed decision. I are a part of the Britt Merris E-Commerce Buisiness Team which helps to educate people who would like to better improve their lifestyle and financial future. One of the steps which we incorporate when talking to people who are interested in making income outside of their career; is to have them check out the Better Business Bureau website, the US Chamber of Commerce website and the ThisBizNow website. All of these resources make the prospect aware of the credibility, and long standing integrity of the Quixtar business, and their affiliate markets. In addition they are introduced to a variety of people to reference within the business team who come from varied backgrounds to include financial analysts, attorneys, teachers, and blue collar workers who have achieved a substantial level of success. It is my understanding that one of the proposals would require giving my name, address, and phone number to prospects who I did not personally speak with. Publishing such a "list " would greatly cause a security concern; placing me, and my business team at risk, as a number of them are single women business owners; some who have children. In addition, as this model of business alligns itself with referral marketing; we would not wish to give the impression that the prospect could sign up with anyone other than the person who initially invested the time and effort to extend the business opportunity to them. Such an impression would greatly skew the concept that you are paid on your own effort, and that we operate with the greatest measure of integrity. To address financial disclosures, after the prospect has been introduced to the business concept, and have met a number of other business owners; they are loaned an SA-4400 document which outlines the income potential approved ty the Federal Trade Commission. They are encouraged to borrow this document for a number of days in order to review with spouse or those who assist them in making financial decisions. In addition, before "signing up" a prospect, our business team is diligent in outlining the steps necessary in order to make thier business profitable. As in any legal business enterprise, there is work required to be successful; and the prospect is made aware that time and effort will be required as we are building for both short-term, and long-term results. There is no "get rich quick" involved; and there are no guarantees. If they feel they are unwilling or unable to phase into the recommended steps to make thier business profitable, then we decide to not sign them up as Independent Business owners. Instead we suggest that they become a customer at no annual fee, and help them to shop for everyday products & services at a greater convenience online. However, it is my understanding that the proposal would require each business owner to provide financial records and substantiate monthly and annual income. Having this information would be misleading to the prospect as it would not accuratley project what moneis the prospect could or would make. Such projections are pending only on the prospects personal time and effort extended into their own business; not on the person or team who is offering the business opportunity to them. This would also greatly prohibit our business growth, as not all businesses grow at the same rate. I am against such provisions of the FTC proposal that would penalize honest Independent Business Owners and cripple their sponsering efforts. I appreciate your extending the opportunity to respond to the FTC Proposal involving direct selling businesses. C.M. Dillingham