|Received:||7/4/2006 11:45:31 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been IBO's since 1991, have been able to utilize the Quixtar business plan to produce a significant income for our family. The opportunity was more than adequately explained to us at the beginning, with particular emphasis on the fact that, like any business, effort would be the major component on our part to build it. It was not a "get rich quick scheme" and there were and are no guarantees of success. Registration including product is under $200 and fully refundable if the prospect changes their mind. Specific Issues: Requirement of 7 Day waiting period: When presenting the business plan, there is no time frame for anyone. We encourage any prospect to get all the information they need to make a quality decision before they decide to get involved. A 7 day "waiting period" is simply not needed. Requirement of Providing References: Totally without merit. From a business point of view, a prospect should check out all the facts about the opportunity which is readily available from any source, but just like any reference in any other matter, someone else's experience is not an indication of the prospect's ability to succeed. In addition, there is a major issue of "cross-lining" that the FTC should understand and look into if they really want to understand this issue. It is a matter of privacy as well. Requirement of Litigation List: There is nothing to hide, if anything we wish the FTC would monitor what is said on the Internet by people who share inappropriate negative information about this opportunity. Rule is totally unworkable at the individual IBO level as we are not party to litigation at Quixtar per se. I believe in integrity, not litigation, and any prospect can investigate on their own anything they wish. There is plenty of information on the Internet (most as indicated above without merit) that can be investigated and answered. Requirement of Specific Earnings Disclosure: Again, this is unnecessary as the overall Quixtar disclosure of average monthly gross income for IBOs is already shared. Simply an undue burden for something already adequately disclosed. Requirement for Financial Substantiation: Totally inappropriate. First, we never disclose our earnings in Quixtar or for that matter in any other business/employment with anyone else, and there are already rules governing this from Quixtar for IBOs to follow. In addition, as a matter of privacy, it is no one else's business how much money my wife and I make in any of our enterprises. The FTC needs to re-think this requirement from a logical point of view. Why should someone be required to disclose their finances to someone else? Again, at the core of presenting this business opportunity, we are always clear that the prospect should do their own due diligence, get all the facts to make a quality decison for themselves, and that our success with the business is becausee of the effort we have put into it. Prospects are encouraged to understand that their success and income is dependent upon their effort following the business plan that is available to them, just the same as it is available to others. We encourage the FTC to re-examine their new requirements and understand that, in their entirety, these regulations would be extremely harmful to individual IBOs and future IBOs with unneccessary regulation.