Business Opportunity Rule #522418-12324

Submission Number:
522418-12324
Commenter:
Pamela Hauser
State:
NY
Initiative Name:
Business Opportunity Rule
I am opposed to the proposed changes on the basis of privacy; this requirement would infringe on the privacy of every IBO whose name, address, and phone number was provided to prospects. It would also penalize the sponsor, who would be required to give his prospect contact information for 10 other IBOs, any of whom might be happy to register the prospect themselves. Eliminate the requirement to disclose past litigation. Among other problems, this requirement would open up Quixtar and other legitimate companies to false accusations. Meanwhile, dishonest companies would simply ignore the rule. If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. Eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied.