|Received:||6/28/2006 8:59:50 PM|
|Organization:||Britt World Wide|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been IBO's utilizing Quixtar as our supplier for 4 years and we have accomplished many short term goals during our business ownership. Our next obtainable goal is to achieve Platinum qualification as described by the Quixtar Corporation. When we registered we received more than enough information to make our decision to register and with progression of knowledge we now provide even more information. Our mentors have taught us to be sure that your prospects get all the information they need prior to registration. Everyone we talk to we inform them that this business takes work and is not a "get rich quick" business. In fact, I ask many qualifying questions prior to even explaining how our business works. The "typical" registration of an IBO includes optional CD’s and getting started right materials for the price of $170.00 and is 100% refundable for the first 6 months. I have a couple of issues with your proposed rules; 1- To provide references of other IBO's for prospects to contact is an invasion of personal privacy. We have a weekly local business meeting with training which allows the prospects an opportunity to meet and associate with the local business owners who wish nothing but their success. By just giving names and address you are opening the door for unethical situations to occur. For example, IBO's talking prospects into registering with them instead of the initial IBO that contacted the prospect. 2-I do not disagree with the litigation list, however I do feel that the list should only have to be provided if the IBO has litigation against them specifically. I do not feel that others unethical choices should be allowed to represent my business or the way my organization is operated. 3- The specific earning disclosure is completely unnecessary. Every prospect receives a detailed document stating all the earning disclosures. Asking us as business owners to give earning disclosures is like asking a car dealer to describe the average income they will acquire using that vehicle or better yet, asking them to tell you in detail how much cost will be incurred for maintenance and repairs over the life of the vehicle. Is this realistic? No, because there is really no way to predict the future of the vehicle as well as there is no way to predict the future of IBO's, and any other business that exists. 4- Financial substantiation: What I make and spend in this business personally is my business and not that of the prospect. The prospect has the ability to make $1.00 or $10 million a year, which is really up to them. It is only my responsibility to provide an atmosphere of growth and education to help the prospect succeed as I have, what they choose to do with my guidance is really up to them. Is it fair to a potential IBO to feel limited by my achievements or even over whelmed by my successes? No, not everyone wants what I do, nor do we have the exact same goals financially. Some just choose to make enough to replace their annual income and others choose to make money with sales not necessarily replacing annual incomes. These are the issues I have for the proposed rules. Everything else seems to be correct in eliminating all the different unethical practices of scams. We appreciate all you do to provide limitations to those who may have unethical or illegal intentions in running business. Thank you for taking my opinions on your proposed rules on direct selling.