Comment Number: 522418-10453
Received: 7/16/2006 2:20:14 PM
Organization: Leno International
Commenter: Nicholas Leno
State: NJ
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear Sirs, My wife and I have been in the Amway, Quixtar business since September 1, 1982. It has been over 23 years since we started our business, and we have been blessed to reach the Diamond level. I am proud to be associated with this company. They have been honorable and ethical, as well extremely fair. I do feel this coporation has been unfairly treated by the general public in certain areas. I have certain concerns, and recommendations. The first concern is prohibiting prospects from registering as IBO`s, until seven days after they receive a disclosure document. The rational behind this in my option is unfair, because in the sales world your are allow 3 days, or 72 hours to change your mind. My experience has been that people will procrastinate after 48 hours to even make a decision that could be so significant in their life. In our business if someone joins, and changes their mind, up to 6 months they will get a full refund. My second concern is to require IBO`s to give every prospect a list of references-contact information for ten other IBO`s in the area. For a brand new person getting started that would be impossible, because when I got started which is true with everyone of us, my first person that became an IBO was my first person. My third concern is to list all legal alligations, law suits, and arbitrations, and other legal claims against Quixtar, and it`s IBO`s from the past ten years. This is absolutely ludicris, since the type of business we have is one in which people come, and go. If the FTC would be willing to list all the positive results in the last ten years, that might be more fair. Requiring IBO`s to calculate and make different disclosures for every income claim. We have been doing that ever the Amway, and Quixtar business began. All of our literature and claims on income are approved by the FTC. The last concern that every prospect recieve substantiation for every income claim. There is absolutely no reason why any of us should have to relinquist our financial records to any person other than the IRS. This business has been all they said it would be and more. My suggestion for a better approach to reasonable regulation would be to have the Quixtar ABOIA board, and the FTC to meet. Sincerely, Nick & Estelle Leno