| Comment Number: | 522418-04725 |
| Received: | 6/28/2006 3:18:50 AM |
| Organization: | |
| Commenter: | Horne |
| State: | MT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
FTC: In regards to the Proposed Rule I would like to offer some insight from our life as Independent Business Owners (IBO’s). My Husband and I have been IBO’s since the conception of Quixtar on September 1, 1999. We knew that this was not a get rich quick scheme, and that the rewards presented to us in the business plan would not come without our own commitment and time. We spent the first several years periodically buying for our own household and continued to renew each year knowing that we may someday want to pursue this as a business. In June of 2004 my husband was called to duty in Iraq for 18 months. I am very proud of his service and our country as well, but with 4 kids and a year and a half, he missed first birthdays, dance recitals, school teachers, pilot lights going out, frozen pipes, and many tearful nights. Needless to say upon his return he started looking for something else to do, and realized he was stuck where he was with no plan B. We are so thankful that we had this business. We do put effort in to this business and we have begun to achieve success. We have found that people all over are searching, some of them praying for another way. We have an answer for them. This business is so much more to us than a bonus check. We have found our chance to get ahead. We have strengthened our marriage as well as our relationship with our kids. Our faith has increased as well as our self image. We are very honest with prospective IBO’s and we would be in support of a measure to ensure honesty. We do, however, feel that the requirement of a 7 day waiting period, requirement to provide references, the requirement to provide a litigation list, the requirement for specific earnings disclosures, and the requirement for financial substantiation would actually harm this business endeavor for us as well as other prospective IBO’s. We have had whole families see this opportunity at the same time and all decide that this would be a great business for them all to enjoy together, this 7 day wait would cost them all. We do not believe that providing references would do anything more than show what one person has done and would not guarantee the success or failure of the prospective IBO. When we are sharing this opportunity we often have other IBO’s with us that may or may not know the prospective IBO. If we were on a list of references in the beginning of our business, we would not have had enough information to provide to a new person that would help them make a decision, this would also have infringed on our privacy. In all fairness, we believe that a litigation list is unnecessary. We have found that if a person is looking for negative information they will have no problem locating it on any business or person. We find that the people that are interested in searching this kind of information out are generally not that interested in building a business anyway. In regards to requiring IBO’s to disclose their specific earnings and financial substantiation, we believe this to be intrusive and harmful to the prospective IBO. We share with a prospective IBO what they can expect to earn as they reach the various brackets, and endeavor to help them reach the goals they set for themselves. We thank you for your work to ensure a great opportunity is not lost to us or any other person. We believe you will find value in this information. Sincerely, Mr. and Mrs. Horne