| Comment Number: | 522418-05013 |
| Received: | 6/29/2006 9:24:29 AM |
| Organization: | |
| Commenter: | Beth Foster |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear FTC, I just became an IBO within the past month. I learned about the Quixtar business in February and took several months to investigate, pray over and decide if it is for my husband and I to pursue. So while I applaud you for being concerned about those with poor decision-making and impulse control skills, I would not have needed the 7 day wait. Furthermore, if it had been imposed upon me, it would have been a hardship as I was ready to make some purchases for my home from our own business (and make a profit off of this) right away. A 7 day wait would have necessitated me purchasing it from a regular retailer in my area and thus losing out on my profit. I learned about Quixtar from my brother-in-law. He lives in Colorado and I live in PA. I do not know of any IBOs in my area to make a list of references for my prospects. This would hinder me as I would not know who to include. Furthermore, should this company have to provide me with a list of local IBOs, I would feel extremely uncomfortable giving it out because I do not know these people or their reputations. I value my integrity and would want others to choose based on those I know. I am an IBO as a secondary part-time business. I am also a counselor (as my main career). If I were to have to do something similar with my prospective new counseling clients (to determine the quality of my counseling) I would also have a problem with this. I would be able to make a list of 10 other local counselors, but I do not know them all personally and again, would not want a prospective counseling client to base their decision about my integrity on what others are doing. The same would go for the lawsuits. I would not have a problem having a site where any lawsuits against myself (or those who sponsored me) were posted for prospects to see (but again, not have my prospects base their view of me on those in the business that I do not know. The business plan that was shown to me, which included a disclosure about how income would be earned, was satisfactory for me. I do not believe detailed and overwhelming financial information would be helpful to most prospects who are not experts in the financial world and would understand what was being explained to them. Again, I applaud you for the intent of your concern....to expose fraudulent companies to unsuspecting prospects. What I am concerned about is that those that are honest, such as Quixtar, would almost appear like there was something wrong about it should you be forced to show this info to every prospect....like I would have to defend myself when there is nothing to defend. My alternate proposal would be to: 1. Have a website where someone could research me (by typing in my name) to see if I have any lawsuits against me. This is comparable to what happens with me as a counselor. BUT, I do not have to give anyone this website or information unless asked, therefore, not looking like I am guilty of anything. If asked, I would gladly give out the site info (again, then I would show my integrity by disclosing the site and would demonstrate my preparedness and honesty) the same as with my counseling prospects. 2. Have a no wait period to become an IBO, but allow one to change their mind and cancel being an IBO within a 7 day period. 3. Be able to ask for a list of other IBOs world-wide that I know personally and could vouch for their integrity and they of me. This should not be a specific number or geographic distance (as with myself, I only know of one other right now and he is across the USA from me). Now as I am more involved, I would have more to add to the list. I would also gladly do so as I would want a prospect to see the others in the business that I know. 4. Be able to show how you would generate income in simple and clear terms but not a full financial disclosure that would only confuse and overwhelm most. Thank you for your consideration of my concerns and my suggestions, Beth