Business Opportunity Rule #522418-12436

Submission Number:
Dwain Marinetti
Initiative Name:
Business Opportunity Rule
My wife and I are Independent Business Owners (IBOs) engaged in the activities of recruiting new IBOs and retailing products to the public. As with most businesses, I have experienced ups and downs in my business throughout its lifetime. I applaud the FTC for wanting to protect consumers of business opportunities from fraud and manipulative recruiting techniques. I believe what we're after here is a level playing field. Unfortunately, the rules proposed by the FTC will give an unfair advantage to the unethical scammers. They will just ignore them or make up any information they need to. An undue hardship will be placed on legitimate small business owners who must comply with the new cumbersome, sometimes intrusive and redundant rules (many of these protections are already built in to the business plans of many legitimate direct selling organizations). Most of the problems can be solved by merely requiring that the Direct Selling Organization proposing their plan to a new recruit have a good, enforceable money back option. For example, the Quixtar business allows a liberal time period for a new IBO to ask for, and receive, a refund of the small initial registration fees, usually less than $150.00 to $200.00. Most products purchased by IBOs and customers have full, no-questions-asked money back guarantees. Also, educational materials have fair return policies as well. These rules give the prospective new business owner a virtually risk-free opportunity to "test drive" the new business. Thank you for this opportunity to express my opinion regarding the new proposed rules.