|Received:||7/2/2006 10:09:27 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have read what the FTC is proposing and I agree with the intent but not the method. I agree that it is important and necessary to prohibit illegal and unethical behavior. However, the methods that the FTC is proposing will not do that. The proposed methods will inhibit the growth of legitimate independent business owners (IBOs). Many new IBOs have no prior business experience. Most are highly educated and very intelligent but have never run a business. The simplicity of our business, Quixtar, is what makes it appealing to them. They don't have the time for a traditional business which requires much paperwork, licenses, and fees, overhead and such. So I understand why the FTC feels the need to make this new proposal. To keep our business accessible, we need to offer people a simple way to start but still protect their interests. First, we should and do require an income disclosure. The plan brochure we use has average income and percentage of IBOs who achieve that income level. Your proposal would require a new and existing IBO to disclose his or her tax return which may contain other private information. Texas does not require a separate entity to conduct business so all income may be reported on the same return. This may be the only financial statement the IBO has. Any new IBO will be reluctant to share their tax return as they consider it private. Requiring the disclosure of personal financial information will only inhibit the growth of legitimate business owners. Second, we should and do require that all new IBOs are entitled to a refund of their initial registration, business materials and any products purchased. In my experience, Quixtar has always honored the refund policy. The same is true for QBIZ.COM which is my team name. This protects a prospect from being talked into any business. This will also allow individuals who need to get started right away to do so. This is an income opportunity. Certain IBOs have immediate income needs. Forcing them to wait 7 days is unfair to them. It is not uncommon to generate income in the first 7 days especially since we do not require the purchasing of inventory. A new IBO may take people a catalog and use an 800 number to place an order. A new IBO may also go to the web and place an order. The new IBO will collect the money from the customer, pay for the order and keep the profit. Quixtar will handle the delivery of the order. This greatly empowers the new IBO. A 7 day waiting period will only inhibit the growth of legitimate businesses. Any other requirements will not serve to protect an individual. I respect what the FTC is proposing. Get-Rich-Quick schemes hurt my business the most because we get lumped in that category. I ask that the FTC put themselves in the shoes of legitimate business owners like me and others building the Quixtar IBO business model. A new business is a fragile thing. These new proposals will only inhibit the growth of legitimate business owners. These new proposals will hurt legitimate businesses. And what hurts legitimate business in America hurts America.