Business Opportunity Rule
FTC Rules committee. I have been a business owner with Amway/Quixtar since 1978. I have not acheived huge levels of success, nor have I become famous, but I have found that this company and its associated business owners have always been open, honest and done their best to keep "bad apples" from harming prospective members. I have made some money (probably 10K over the years), enjoyed the compassion and companionship of highly motivated and ethical, successful people and have learned a lot about personal growth. In other words I am NOT one of those who got rich quick (or slow) here. But I have a lot of experience with the people, the corpopration and the way in which prospective business members are treated. I am commenting on three aspects of the proposed rule. There are problems with all aspects but these three give me the greatest concern. First, the financial disclosure section. My income is not public information. I strongly object to having my private records having to be disclosed to prospective members. I also find that such a requirement is misleading. I am not actively pursuing this business. If I were to start doing so, my income would be totally misleading as I earn just a few dollars from retail sales & small bonuses. A person wanting a larger income might not want to be involved with me as I did not show great success, even though I would be pursuing it at that time. Second, the requirement for providing a list of references of business members in the area. This requires my personal information to be given to many people who I don not know and who I may not want to have my name & address available to. This is an unreasonable invasion of my privacy. And not all people are honest & trustworthy. I can think of several potential criminal uses of this information. As an example, as a professional burgular, I would love to have a list of addresses where people may not be home in the evening because they would be @ business meeting! A great tool for robbery. Think of the potential problems here. Additionally, As I am not currently trying to expand my business, I do not want a large number of people to have my name & address! People call @ wierd hours & with a wife & family I want to ensure our privacy. I know from experience that prospective business members regularly are invited to meet other prospects & members at meetings where they can discuss the business and issues. This seems to me to be a sufficient effort to make additional contact information avaialble. Also the requirement to make a list of area members available can lead to the possibility of prospects joining another person's business. Say one "more convienient" or with more status. Thus you are potentially depriving someone who is "poor" but ambitious of potential business. People ARE still snobs & prejudiced. Third, I find the watiting period requirement to be an unfair burden and a problem. First, even to do a 100K equity loan only requires 3 days! Second, the process that Amway/Quixtar has used to protect prospective members for years, is a good model for the industry. I sugest that you contact them and model any proposals in this area around their policy. I have found that this process really does protect the prospective members without placing an undue burden on the business owner. Again I have concerns about more of the rule but these are the greatest issues. Thank you.