| Comment Number: | 522418-05828 |
| Received: | 7/3/2006 7:12:35 PM |
| Organization: | Quixtar |
| Commenter: | Dinesh Kumar |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Hello, I was registered with Quixtar, Inc. over 3 years ago by my best friend.The kind of personal growth and business savvy that I've learned can't be measured just in dollar amount. It was made clear to me that this is a business opportunity, not a get rich quick scheme. I tell the same information to my prospects. However, I'm bothered by a few points of the proposed rule The requirement of a 7-day waiting period - This can be a good rule, but given the fact that any and every new business owner can deregister and get their money back makes it redundant. I make it very clear to them that this almost all of their startup money is refundable. And I've had people take advantage of that offer. All this rule would do is for people to hesitate more. Starting your business is not an easy task to begin with, why make it harder? How many people would jump in the swimming pool for the first time if there was a waiting period of 7 days where you would constantly look at the pool, but would not be allowed to jump? This would definitely affect my business negatively and make a legitimate business seem spurious. The requirement to provide references - This is a total breach of privacy and the business model. I know how I would feel if my contact information and name was given to any and every stranger who decided to look at the opportunity. How valid it would be if after my hard work of explaining the opportunity, the prospect is able to register with one of the references. What's the fairness in that? The potential financial loss can be substantial for my business. Besides, almost all my prospects are given the opportunity to meet the busines team (i.e. other IBO's) before they register. Again, this infringes on privacy and doesn't serve any worthwhile purpose. Requirement to provide a "Litigation List" - How many companies are required to provide this list before hiring new employees? What does my business have to do with a million other IBO's who conduct their business in a questionable manner? When was the last time business owners that operated in the same industry were REQUIRED to be affected by all others in that industry? When was the last time a candidate was told ALL the problems that have happened involving the senate in last 10 years? Ridiculous? Exactly. Do I get a similar list if I decide to buy a franchise of my own? What is a "seller"? Doesn't this mean that the FILED cases would need to be listed as well? This is a tremendous waste of time, money and energy on an IBO's part. I know if I would've gotten this list, I won't have started. And that would've stopped me from taking advantage of the best business opportunity. The requirement for specific earnings disclosures - We tell prospects the average monthly income an IBO makes. It's part of the literature that we provide to them. SA-4400 has relevant information as well. Given that, this requirement isn't meaningful at all. If I got started tomorrow, how impressive would my earnings disclosure would be? If I'm making separate disclosures everytime discuss income, how fluent and effective is my presentation? Have you ever tried it? Who wants to listen to disclosures for, say 10 examples in a presentation? The requirement for financial substantiation:- I only share my financial records to authorities. Why would I show it to prospects who are not even my associates yet? I do tell them, truthfully, how has my income been affected by the opportunity. But to have to substantiate with my records is a serious breach of my privacy, and dignity. If you want the best perspective, walk in my shoes for a month, and see how these rules feel when you have a business. Thanks for your time. Hope you seriously reconsider the points I discussed. Regards Dinesh