Comment Number: 522418-04364
Received: 6/26/2006 5:27:12 PM
Organization: Independent Business Owner - Quixtar
Commenter: Benjamin Hirsch
State: AL
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

First I want to applaud the comission for setting out to create regulations on buiness opportunities. There are many companies that fairly promote their opportunities but there are also those that don't. In my own experience, I have been a Quixtar Independent Business owner (IBO) for 10 months and have had success with this opportunity. My goal when I entered the business was to create an extra income stream of $1000, which is enough so my wife and I could have a child and pay for some of the expenses. We have been able make, part time, around $150-$200 a month and it looks like we will hit our goal of $1000 within the next 12 months. The business people that introduced me to Quixtar have been completely honest and I never felt like I was lied to about this opportunity. In addition, when my wife and I sponsor others, we correctly apply all the rules and regulations that Quixtar has set out. By doing this (and reminding our prospects of the money back guarantee) we have not had any of our IBO's complain to us about giving misleading statements. There are a few issues I would like to address about the proposed regulations. First is having a 7 day waiting period. People, whether in school or in business, only retain a small amount of information that they are given/taught. Waiting 7 days would amplify this effect tenfold. Also, a 180 money back guarantee (like Quixtars) could allieviate any buyers remorse that occurs. But in a network marketing business, if people are not kept interested, they certainly forget and often never realize any additional income they could have received. The second issue I have deals with requirements to provide references. While I understand how this could help with scams, it will also hurt network marketing organizations. If I gave references to 10 other people then the new person could likely just sign on with one of those people, nullifying any potential gain. Also, my wife and I live a fairly private life and having my name and address would feel like an infringement on my civil liberties. I do not wish to have my personal information given to complete strangers. A litigation list could deter potential IBO's out of fear for no reason. Giving any accusations of a billion dollar company like Quixtar is very unnecessary. Is an average stock investor sent litigation materials for 10 years on that company before they are allowed to buy stock? The answer is obviously no. Specific earnings can be useful when understanding a business plan. In the Quixtar business opportunity, it was show to me as the average active IBO earns $114. This makes sense because people should know how good the opportunity is. But disclosing the earnings at every level in the business can be misleading. Like any business, earnings vary based upon effort and structure. Lastly, I do not agree with making prospects aware of how much I make in business. Now that I am making enough money to be believable it is alright. But when I was "training," I was making no more than $10 a month. But do we ask colleges how much money their students make. No because they are learning a trade. Same idea applies with this business. We must learn and grow our skills so we have to opportunity to make more money. While I very much want a better atmosphere for small business opportunities, some proposed regulations would hurt myself and many other IBO's in the business today. In essence building a business would become so difficult we would be forced out. I believe that many network marketing companies IBO's, consultants, etc. would be driven out of the market and lose any extra income they hoped to gain. Network marketing remains one of the best ways to gain extra income for the average person in the United States. Any laws hindering this would be laws against the citizens of this great nation. Benjamin Hirsch,  Quixtar Affiliatied IBO