|Received:||7/3/2006 12:07:41 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I appreciate the fact that the FTC is trying to regulate bogus business opportunities in order to protect individuals. However, as I read over the proposed regulations I am concerned about how they would affect the business my husband and I have begun as IBO's (Independent Business Owners), powered by Quixtar. We have been IBO's since Quixtar began 9/1/99. Our business has had steady growth, but not fast growth. We know that one grows according to the work one puts forth. We have reached a level known as Silver Producer. Our next goal to to reach the Platinum level. We have enjoyed some financial income, however another area of growth is in personal development. Through our associations with others in the organization, books and audios available, we have definitely grown as individuals. I would like to address 5 points of which we have concerns. 1. The first says that a prospect may not register for 7 days after receiving information. This would not benefit the sponsor or the prospect as it puts a burden of added time on registering. Both may be anxious to register friends or family and this slows progress. A better solution would be to offer all money back if not satisfied, something Quixtar does at this time. 2. Another proposal says to give every prospect a list of 10 references in the area. Giving names, phone numbers, addresses would infringe on their privacy. Also if I am the prospective sponsor I feel it unfair for those 10 people to have the opportunity to perhaps sponsor my prospect--one I have worked to develop. I think this regulation should be eliminated entirely. 3. As to listing all lawsuits, allegations, etc. against the company in the last 10 years, I feel this would open things up to false accusations about honest companies and dishonest ones simply would ignor anyway. Eliminate this one also. 4. Create a level playing field by disclosing standardized income. As it reads it seems very complicated. I feel it would be better to state, as Quixtar does on material that we share with prospects: "Average monthly income for 'active' IBOs is ____." 5. I do not believe that financial records of individuals should be required to disclose to prospects---it's a matter of privacy. If the FTC requires it or a state agency doing an investigation requires it, that is different. New prospects spend about $45 to register, plus $100 to $125 on products they wish to purchase. They may also buy a kit for about the same price. If they are not satisfied all is guaranteed 100% and money is refunded. We feel that is an excellent way to protect prospects. All prospects should understand that any business takes work to succeed. Quixtar is not a "get rich quick" business and is not represented as such by any material we provide our prospects. Thank you for your work in this area, but please do not penalize those of us who are working honestly as Independent Business Owners by implementing the above listed items.