| Comment Number: | 522418-05001 |
| Received: | 6/29/2006 4:57:56 AM |
| Organization: | Piercent Business Group |
| Commenter: | Robert Pierce |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Gentlemen: We are writing about Part IV Federal Trade Commission 16 CFR Part 437, Business Opportunity Rule; Notice of Proposed Rulemaking. My wife and I are retired workers who spent over 55 years working for someone else. We now are enjoying the benefits of working for ourselves through the Quixtar.com business opportunity. The income we earn from Quixtar is very helpful in supporting us in our retirement years and we feel privileged to be able to offer and help others. We are very supportive of any efforts by the FTC to ensure that every prospect has the information needed to make an informed decision before starting a business opportunity. We dislike many of the “get rich overnight” claims and we work very hard to distinguish our business opportunity from them. I’m sure you will see that Quixtar stands out with its well known integrity on this issue. When my wife and I approach any prospect to sponsor them as a new Independent Business Owner (IBO) we want them to have all the necessary information to make an intelligent decision. This is best for us as well as them because this avoids wasted time and effort in training them on how to be successful. We tell them, there is no such thing as something for nothing or “get rich quick”. We tell them it takes time and their personal growth to build a secure profitable business. Our prospects usually spend about $140, which includes some sample products and literature, to get started in the business. Some chose not to take the sample product portion and spend only $50. Whatever they spend is fully refundable if they decide to leave the business. Here are some difficulties with the proposed rule changes from our perspective: A 7-day waiting period would be too cumbersome to keep track of and entirely unnecessary since Quixtar will always refund any money if the new IBO decides this is not for him. The possible requirement to provide a list of references would be an invasion of privacy for the referenced IBOs. Often a new prospect is able to talk with several other IBOs at our meetings before they join. Also, Quixtar has several very informative web sites that give them “references” of successful IBOs as well as realistic facts about the opportunity. All of our literature given to prospects indicates the “average monthly incomes of active IBOs”. The proposed requirement to hand out information on all lawsuits, etc regardless of the truth of the allegations made, would be like asking GM to hand out to potential customers all of their legal challenges, right or wrongly formulated. This is not realistic or necessary where a prospect can have all their money refunded. Requiring a disclosure for each income claim made in a presentation should only be a simple statement of what the average IBO earns – which is exactly what Quixtar has done for years. There also should be no requirement to disclose personal financial information about a sponsor’s Quixtar earnings since the Quixtar opportunity is only based upon the prospects’ goals and efforts – the sponsor’s income earnings neither helps nor holds back the level of achievement the prospect can reach. The Quixtar earnings potential that we discuss with prospects are only those that the corporation has had approved by the FTC - that is the only requirement that should be maintained. Please continue to weed out the improper and misleading business opportunity scams but don’t make doing the Quixtar business unnecessarily complicated. The $50 to $140 startup costs which are fully refundable do not warrant the burden of the proposed rule changes as currently written.. Thanks for listening to us. Sincerely, Bob and Mary Pierce