|Received:||6/28/2006 11:25:36 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar IBO for over 13 years. Over 11 years ago, I was able to replace my income as the Admissions Director of a private school and come home to raise my children and continue building my business. I have always provided the income projections published in the SA4400 when I've registered a new partner. The registration fee with product pack of their choice is entirely refundable and so are any training information new IBOs may elect to purchase. The proposed changes to the FTC rules penalizes a entirely legitimate business by throwing it into the pot with illegal business models. The seven day waiting period would significantly slow a new IBOs progress in reaching that momentum necessary for a viable business in our field, and, personally, I believe all my time would be eaten up by responding to requests for referrals if the referral rule were instated. Also, there is the real risk that my prospects might decide to register with someone they've been referred to -- who hasn't done the work of showing them the business plan and following up numerous times. The disclosure of all lawsuits is truly unreasonable, since we live in a litigious society and there is no proposal to also reveal how specious the suits may be. As far as revealing my income, I believe supplying a range of incomes for people who are at my level in the business is appropriate, but providing my exact income is an intrusion into my private business. I understand the motivation for the rules being proposed, but it is clear to any IBO who has successfully built from this excellent model that these rules would significantly inhibit people from reaching any appreciable level of success in their home-based business. I have been able to help several families retire a parent, eliminate debt, and begin to contribute to their communities. I would hate to think these possibilities were being removed because of unethical practices elsewhere. It seems it should be possible to examine the compensation plans of the offending businesses (1. does the money flow up from the people joining -- rather than flowing down as bonuses from major corporations -- and 2. is the business in question position or performance based?) In our model, cash flows down and it is clearing performance based -- anyone who joins me can exceed my income if they put in the work, which I always explain to them. Thank you for providing this forum for comments.