| Comment Number: | 522418-04457 |
| Received: | 6/26/2006 10:56:36 PM |
| Organization: | |
| Commenter: | Brennan |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I support rules that require income disclosure as far as what an average direct seller actually makes in a business, but feel that substantiation of actual income puts an unfair burden on direct sellers. No other businesses require that kind of substantiation, and while I'm certain the reason is to weed out wildly inflated claims, it hurts the IBO who is just starting out and who still has only limited earnings. With regard to requiring IBOs to provide prospects with a list of references 7 days before the prospect registers, I am opposed to that as it hurts an IBO's chance to succeed. As everyone knows, there is a certain amount of risk in any business decision, and to overcome hesitation about taking a risk, the best choice is to take the plunge. Even though registering with Quixtar would be low on the risk factor, considering the low cost of business startup, there is still the element of time to consider that a prospect may decide against. Contacting references and a 7-day wait period for registering would slow down the process so much that IBOs and prospects would be very discouraged. Lastly, the idea that lawsuits or past litigation brought against Quixtar and its IBOs be disclosed would give a prospect a false impression about the company. There are frivolous lawsuits and some that may have some merit, but those that might have merit don't involve Quixtar directly, but rather the IBOs who have chosen not to follow the rules and laws that are in the Quixtar by-laws. To penalize the company in that way would be detrimental to the company and IBOs.