|Received:||7/1/2006 4:53:15 PM|
|Organization:||McGarvey Enterprises International|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My Quixtar Experience: I have been an IBO for about 13 years, and consider it to be the most ethical, legal form of Free Enterprise that I have been blessed with. Before my wife became ill and left this life in 2004, we found this business opportunity allowed us to set and achieve goals and work for ourselves while maintaining our overall lifestyle. We enjoyed the professional way in which Quixtar introduced us to this opportunity via another IBO.....honest, straight-forward, no get-rich-quick...complete with FTC approved documentation. When I share this opportunity with other prospects, I adhere to the same standards, leave materials ( including the SA-4400 ) and get back to them in a follow-through meeting to answer questions, and to move forward with them as a new IBO or as a potential customer. Most of my new IBOs spend about $125.00 to register( less sales tax and delivery fee ), though some will opt out of the Product Info Pack ( $60.00 ) which allows them to experience some standard products if they so choose. Up to $94.00 is refundable if they decide to leave the business within the first year. Besides income, we enjoyed the ability to share this business with others as a bonified broker on behalf of our product and service partners, as well as a tutor to those who wanted to become an IBO. The opportunity to attend business meetings and conventions allowed us to stay abreast of market and product changes, all of which were conducted in a professional and ethical manner. This business instills trust and respect, accountability and responsibility, and a positive attitude for the entire family and organization. Comments on Proposed Specific Issues: General comment: I believe the current business disclosures set up by Quixtar and our IBOAI are sufficient and reasonable to enable potential consumers and new IBOs to make wise choices. 7-Day Waiting Period: Do NOT concur. This is a Direct Selling business involving my own time and travel to the prospecthome or place of business which we have mutually agreed upon. A complete presentation is made, and sufficient materials left until a Follow-Thru meeting within the next 24-48 hours that we agree upon. The prospect may register at that time or later, but a 7-day delay beyond that is unresonable and would require unneeded EXPENSE again to return to the prospect and review the same information, not mention an unneeded delay in building profitability...not only for me, but for the new IBO. In particular, it would be an unnecessary requirement if friends or family members wanted to get started. I see no benefit for the prospect to have to wait 7 days, especially since we provide the necessary FTC approved materials and are backed by the Better Business Bureau. Providing References: Do NOT Concur. When I present this opportunity, I mention that I have the availability of contacting my sponsoring upline. To provide IBO references such as downline or IBOs in other organizations is not acceptable since they have no idea what I have been discussing, and they could sign that prospect into their business. This is also a privacy issue where I might not feel comfortable being required to give my address and phone number to let other IBOs give to prospects. Besides, the prospect is encouraged to meet other IBOs in my organization andmy sponsors in an informal Open Business Meeting to learn about their experiences. Providing Litigation List: Do NOT Concur. Unnecessary. Quixtar is available to answer a prospect's questions; the proposal does not adequately cover what a "seller" is, i.e. IBOs may have to list all litigation involving Quixtar itself as well as the entire IBO force across the country, and would not be limited to cases found against the seller but even those filed with no merit. Financial Substantiation. Do NOT Concur. As with any other business owner, a requirement to offer my financial records to anyone except as required by reasonable law is an invasion of my privacy.