|Received:||6/26/2006 9:27:17 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My husband and I have been involved with the Quixtar business and its precessor for 10 years. During that time my husband and I have reaped many benefits that go way beyond the income we have yearned. It has been both our observation and our experience that people that we have seen introduced to this business or that we have ourselves introduced to this business are almost always cautious. Prospects are given ample information to evaluate the business opportunity and are invited to meet other members of our team. There are no guarantees regarding engaging in any business opportunity or job for that matter. With all due respect to the goals of the FTC proposals, the types of precautions outlined in the FTC proposal seem excessive in light of the fact that direct selling businesses have flourished over the last several decades. My husband and I believe that such proposals would seriously hamper legitimate direct selling business of all kinds. For example, when we introduce our business to a prospect, we share with them a disclosure document created by the Quixtar corporation. Furthermore, all marketing literature we use discloses that the average IBO made $115 a month. We think this is a discouraging amount, although the income potential is certainly far greater. We explain that it will take work and time to be successful and we explain the start-up and ongoing costs. We leave behind further explanatory literature and invite prospects to come to a training seminar. It is my understanding that there is a money-back guarantee on most, if not all, start-up materials within a certain period of time. Providing references creates 2 problems -- 1st, a reference could prospect my prospect; 2nd providing such reference info could become an invasion of privacy. Providing a litigation list as outlined is so all-encompassing that it is hard to imagine how an individual could compile such a list. Such information is more than adequately available through the internet and in our experience has chased away more than enough prospects. Regarding Specific Earnings disclosures and Financial Substantiation would also put an undue burden on new IBO's as well as longer term IBO's who may have been slow in getting their business off the ground. The relevant information to the new person is not what have I been able to achieve, but what is the potential for them. There are too too many stories of a person who did not do much with the business, but who introduced the business to someone who became a great success. We believe that a specific money back guarantee for a period of time for all start up materials would be more than adequate to protect the public. Specific disclaimer requirements, such as those required by Quixtar, are more than adequate to discourage people from becoming involved. We feel strongly that the proposed rules would seriously damage our business and would discourage us from continuing to pursue our dreams and we respectfully request that the FTC consult with the serious direct marketing businesses before taking such drastic action.