|Received:||6/28/2006 7:43:34 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To Whom It May Concern: I have been an independent Business Owner with Quixtar for nine years. I believe the direct selling industry is vital to the people in this country and provides them with the means to improve their lives without placing a burden on the government and thereby, their fellow Americans. Having been around this industry for so long and having seen different “opportunities” come and go, I understand the need to make sufficient information available to the prospective client. The right information would significantly prevent people being scammed by outrageous claims and would serve to strengthen our industry. However, we should do it in a way that does not adversely affect the companies and individuals who are currently providing adequate information and a genuine opportunity. To do so would only produce a net, negative affect on the industry and thus serve no one. On the 7 day waiting period: If the intent of this proposed measure is to ensure that the prospective client has time to receive enough information to make a proper decision and to reduce the risk of being deceived, I understand and agree with the goal. I do not agree with the method. The majority of direct sellers are regular everyday Americans and such a requirement would cause a logistical nightmare. Having to keep track of exactly when you talked to each and every prospective client and whether today is day 6 or 4 or 8 before you can ask for the sale? Not to mention the added expense of yet another phone call and probably another trip (at today’s gas prices) to close the deal. I think that the reduction in risk that is being sought by this proposed measure can more than adequately be achieved by a no questions asked money back guarantee. Such a guarantee already gives the prospect a far longer than seven day (usually 30 days and up to 1yr) period to evaluate the opportunity and even reconsider at no risk. On Earnings Disclosures: Once again, this is overkill for Quixtar IBOs. We already provide every prospect with form SA-4400, and FTC-approved document that discloses the incomes that can be expected at each level as well as how the incomes are calculated. In addition to this, Quixtar releases income data each year detailing how much was paid to the direct sales force and what the averages were for each income level. Perhaps everyone should do this. If you would like to use Quixtar’s methods as a benchmark, then the industry would be helped tremendously. I do not see, however, how any additional information would help the prospective client.