Business Opportunity Rule #522418-11452

Submission Number:
Lowell Martin
Initiative Name:
Business Opportunity Rule
I'm concerned with the negative impact on business of the new ftc proposal. I understand the dishonest nature of many so called opportunities and favor regulations to prevent dishonest methods; however the current proposal will significantly hurt new business owners in legitimate business that requires recruiting. People become disgruntled because of lack of results the following will only slow results. Points of the proposed regulations that pose a problem: 1. 7 Day wait to register: It is the goal to have new business owner registered and have them seeing success as fast as possible. Requiring a 7 day wait will slow the results for a new business owner significantly. In a job they get a paycheck their first week. Implementing this rule prevents them from even registering their first week let along get started. 2. Providing a list of references: This is easy for the already successful business owner but as sever negative impact for the new start-up business. The only references they could provide would be those that are their competitors. The new prospects should be the ones providing a reference since the person getting them started is investing significant time an energy into helping them get started not the other way around. 3. Listing lawsuits: First. In today's society anyone that produces is prone to being sued. Second, specifics are needed to specify that the term "seller" cannot broadly group one independent agent with all other independent agents since they are not governed by each other. Multi-level businesses frequently operate with many independent agents. Forcing the disclosure of lawsuits against other business that operate independent from each other is highly unfair. If disclosure of legal action is implemented it should be confined to convictions of a crime not lawsuits and apply only to the corporation or if specific person doing business with that company. Others doing business with that company should not penalized because one person associated with that company was dishonest. 4. Disclosure of income: This regulation would substantially hinder those starting in business. Individuals that have attained success can do this easily but what about the new person starting in business. Requiring someone to disclose their own personal finances would be like forcing a business to tell his employees how much the owner earns during an interview. The current requirement to disclose the average income of individuals that attain a specific level is very sufficient.