|Received:||7/4/2006 11:21:02 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO with Quixtar since Feb 2005. My income from this business has been slowly growing but in direct proportion to my efforts. The statement that this is not a get rich quick concept was explained to me at sign up and I explain it to all those who I register. Prospects typically spend $225 to register and for an introductory product pack, all of which is refunded in total if not satisfied with the products and business concept. I have reviewed your proposed rule and feel that while it is a great idea to weed out the illegitimate opportunities there are a few points that can cause unnecessary hindrances to legitimate businesses. One of whice is the proposed 7 day waiting period. If the 7 day waiting period was enforced, inspite of the lost enthusiasm, the prospect would have to wait an additional 7 days to sponsor any friends or family and thus causing them immediate frustration and postponement of income building success. The wait period should be eliminated, especially in the cases like Quixtar that offer a 100% money back garauntee! Another problem point is having to provide prospects with references. This causes problems not only with an intrusion into individual's privacy, but into the basic building structure of "he who does the work gets paid." By this I mean if the prospect contacts another IBO, the contacted IBO the may have the opportunity to sponsor the prospect themself without having put forth the effort to explain the system to the prospect (or any of the other work/information the proposed rule requires). Also, the point on specific earnings disclosure should be able to be limited to a specific, legitimate statement like "the average monthly gross income of an active participant is _______." Very rarely would disclosing anything more that this be any use to the prospect. With legitimate busnesses, if the prospect wished to get more detail, they simply need go to the internet or some other means(i.e. BBB) to research and find out the desired information to confirm/deny the suggested statement above. As far as financial substantiation goes, on a personal level, that is something that should be left completely up to the individual showing the plan to volounteer. For example, if a new IBO was showing a prospect how they could achieve their financial freedom but since they were new would have to advise the prospect that they had only made $xx.xx so far. This can shatter any belief the new prospect may have as well as frustrate the new IBO. Again, I feel it is important to come up with some way to stop illegitimate schemes but it needs to be done in a manner that does not hinder legitimate businesses. I hope that my comments do not fall on deaf ears and bear some usefulness in determining what is in the final rule. Thank you.