| Comment Number: | 522418-11181 |
| Received: | 7/17/2006 6:31:11 AM |
| Organization: | Leatherwood & Associates |
| Commenter: | Calvin Leatherwood |
| State: | NC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Please review for consideration 1. Prohibition from registering as IBOs for seven days after they receive a disclosure document. **No prospect is ever required to reveal past failures or successes, they are accepted at face value until their conduct dictates otherwise which we believe is fair since assistance is rendered based on what they want rather than their past. Please be careful to that you don't steal the people rights to choose at their discretion that you're striving to protect.** 2.Require IBOs to give every prospect a list of “references” – contact information for 10 other IBOs in the area – seven days before the prospect registers. **To my knowledge, no other franchise, corporation, employer or university (all of which offer an opportunity) has ever been required to list references, percentages of successes and perceived failures, starters or finishers. Each offer an opportunity and a chance to create a better life with better options. The number of people working with honest, upright standards by far out number the dishonest. However, we will placed be under the same scrutiny as the criminal, derelict, and scammer and our rights are compromised. I agree, make effective guidelines but with more stringent punishment for violators. Please don’t handcuff our credibility and success by forcing our to defend the possibility of broken trust at the onset of every business relationship.** List all legal allegations – lawsuits, arbitrations, and other legal claims – against Quixtar and its IBOs from the past 10 years. Require IBOs to calculate and make different disclosures for every income claim. Require that every prospect receive “substantiation” for every income claim. **Larger businesses and corporations are far more likely to cut corners and bend the rules that the average citizen that normally honest in their dealings. If the same standards were applied in other businesses a lot of owners, CEO’s, etc would not exist because past would alter their futures but these people are seemingly more difficult to control. In your deliberations, do make more difficult the hope for a better life that already a fragile commodity. Question for consideration, does the IBO get the right to the same information in kind from prospect and where does the breach or violation of privacy stop. It appears there is another agenda in the balance, how much hope do you steal from the many because of a few. Make no mistake about it, you are asking IBO’s to appear guilty and prove themselves innocent. It is very easy to make decision from afar without seeing the impact or collateral damage of your decision. Please consider us!**