| Comment Number: | 522418-05667 |
| Received: | 7/2/2006 10:55:11 PM |
| Organization: | Stow Enterprises |
| Commenter: | Barbara Frank |
| State: | MA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am deeply concerned over the proposed changes to the rule for Business Opportunities. While I appreciate the FTC trying to crack down on illegal scams, the measures proposed will hurt those of us that operate legitimate businesses. My biggest concerns are: 1.) The seven-day waiting period - this is more prohibitive than buying a gun. No pun intended but this is overkill. Those of us that are associated with Quixtar all ready meet full disclosure with our prospects by offering them an approved document (SA4400), all our literature has average incomes, and by offering a money back guarantee for six months on any products they order. To join our opportunity is $56 plus the cost of any products they purchase - most people spend a between $125 and $200 to get started in their business. Additionally, we direct prospects to www.thisbiznow.com, which gives them a tremendous amount of information. For most people this opportunity is an addition to their current income - and our prospects are extremely time starved. When I started my business twelve years ago, I was a National Account Manager and was traveling all over the country - if I had to wait - I probably wouldn't have started just due to my time constraints. I actually asked to get registered that night. Most people register the first time they see the opportunity and start to buy products through the Quixtar website right away. The seven-day waiting period would prevent them from capturing immediate profit and would give the neighborhood store an unfair advantage. The waiting period could also damper their initial enthusiasm and create doubt in their minds. Why would they have to wait for this business when the initial investment is so low? 2.) Disclosure of our financial records - this is a complete invasion of our privacy. We also own a custom picture frame shop. The only people who know our financial picture is our accountant and the IRS. We never would disclose our personal finances to our employees, prospective clients or vendors. Giving a standard average income disclosure is fine - we do that all ready. 3.) As for disclosing past litigation of other IBOs - this has nothing to do with how we operate our business. We don't tell our frame shop customers about any litigation from other frame shops. Why would we need to discuss other IBOs issues? They have nothing to do with our business. We operate according to the Quixtar code of conduct and ethics. Additionally, any prospect just needs to Google us and they can find out as much as they want about others issues. 4.) We should not be required to give our other IBO references. This could cause great harm to our business - as our prospects could then join others instead of us. It also alerts other IBOs to our personal activity. This again is like sending our frame shop customers to the shop down the street when they aren't competitively shopping around. Owning and operating a Quixtar affiliated business has meant everything to our family. I just turned down a promotion with an increase in salary of $25,000 per year - as I didn't want to take time away from my Quixtar business and my family. We work the business together. If this proposal is enacted it will negatively impact us as a family owned business. Perhaps the FTC can have a clearinghouse for companies like Quixtar that all ready exceed the standards you are trying to enact. Being approved we could be exempt from these onerous burdens. Sincerely, Barbara Frank Mitchell Sprung