|Received:||6/30/2006 6:35:56 PM|
|Organization:||Independence International Associates (Quixtar-powered)|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:We applaud the intent of the proposed rule. Let's make sure that it helps the "goose lay its golden egg" rather than "killing the goose". The purpose of a business opportunity is to help the both the recruit and the recruiter increase his/her earnings, and thereby stimulate the economy of the Nation. - A person seeking an additional source of cash flow often has a degree of urgency. Making this person wait 7 days before s/he can start the business is totally unfair to him/her, especially when this person needs to start to build his/her network/customer base immediately. A new recruit simply does not have the earning history, data about past litigation, and other detail the proposed rule indicates. What s/he DOES have, in our Quixtar-powered business' case, is full disclosure by the Corporation as to how earnings are calculated, and the average earnings of an active Independent Business Owner (IBO). S/he can view the website www.thisbiznow.com, and www.quixtar.com. Given that this information has satisfied all new IBOs whom we recruited in our 20+ years in the Business, forcing us to disclose private information about our personal business is both unnecessary and unfair. Take the scenario of a "spy" posing as an interested party: s/he finds out private trade information about what we do then sells it to our competitors. Not nice, and probably unconstitutional. The main point here is that the only way anyone can earn income in our Business is to create product sale volume: s/he will be paid strictly according to it. How, exactly? This is information we supply, accurately, during the recruiting process. The issue of references in our area could not apply to our business. We are an Internet-based CYBER-MALL, with IBOs and customers scattered all over the Country. More often than not, we don't know enough others in every area where we link up a new IBO, to satisfy the proposed Rule. Given that there are MANY competitive lines of sponsorship in our business model, dealing with people "cross-line" is unhealthy, especially in a remote location. For example, we do a lot of work with a prospect far away, we refer him/her to some local stranger for reference who then, in turn, recruits OUR person, claiming that being "local" is an "advantage". We lose a prospect. Others might be scared to recruit remotely . Unfair: in our business we respect the sources of all connections. We make it a point to introduce all new recruits and THEIR new recruits to the organization (Line of Affiliation) and support system of which we are a part, just as soon as possible: this could be a weekly meeting or a periodic seminar. Quixtar and we offer an iron-clad money-back guarantee on the registration fee, products and business tools, just in case the new recruit changes his/her mind. Consider that a new IBO's investment is around $50 for a registration pack which includes catalogs, the Rules and access to a 15,000-page INCREDIBLE shopping-and-business-management website for the new IBO to use immediately. All other investments, such as products and business tools, are optional, and are clearly stated as such on the registration document. We recommend a mix of education tools and products for the new IBO, based on his/her stated business goals. Often we need to educate a new IBO about BUSINESS thinking versus CONSUMER thinking, a process during which the new IBO lays the foundation for achieving his/her business goals. Let's make the recruiting process as suspicion-free as possible: the new person often doubts his/her ability at this point, anyway. More importantly, let's help the novice build HIS/HER network FAST, so s/he can learn fast, and become successful fast. The proposed Rules would make the DUPLICATION process incredibly cumbersome and scary. Novices would stay away, thus "killing the golden goose". Suggest you look at what the rules are by which Quixtar and we operate, and make THIS the standard for other Direct Sellers.