Comment Number: 522418-06047
Received: 7/5/2006 4:48:43 AM
Organization: Team GlobalNet / Quixtar
Commenter: Frances Collicott
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Way to go! We are excited to know about the work you are doing regarding integrity within direct sales opportunities. It will really be beneficial to us. However, we would like to make recommendations. We have been IBOs since September 1987 (19 years). Some of the benefits have been increased income, increased lifestyle, mom not working outside of the home, strengthened marriage, great friendships, character development, improved financial intelligence, peace of mind about our financial future, improved communication skills and greater confidence. The list could go quite a bit longer. We have worked hard over the years to create a secure foundation of repeat consumers and trusted teammates. We will continue to do so. When we registered, we were enthusiastic about learning what others already knew about making income other than as an employee. We were loaned many tapes and plenty of information to consider. Registration had no risk attached, so we didn’t wait to become an IBO although we had a lot to learn from that point. We provide prospects with more information than they can sometimes take in. We want them to trust us, trust the business model, know that there is no risk, and that we will respect them and deal with them with integrity. We want the income to be LONG TERM and our time to be INVESTED and not spent. Education is the only way for that. A main reason for a new IBO to not progress toward there goals is lack of education. They must know there is a learning curve and it is not get-rich-quick. When they are assured that work, cooperation, and collaboration is required in order to really profit, then they know we are dealing honestly. Before we register anyone, they are provided with a bundle of information (including the “average income of an active IBO”) and asked to review it and ask questions. We strive to register IBOs with a sample product pack, but they are told it is optional. We let them know the startup costs are all refundable if they change their minds. We are glad to give the refund ourselves, but the corporation will do so by a quick signed written request from the new IBO. Not a problem. Recommendations: Instead of a 7-day waiting period before registering, require a signed/initialed acknowledgement of a money back satisfaction guarantee on the registration fee and startup purchases. Many places don’t have that guarantee or it’s not announced. We are very proud to announce it. Instead of a requirement to provide references, require that the contact info of the upline platinum and the corporation’s business support phone number be provided and acknowledged by the prospect at the time of startup. Instead of requiring IBOs to provide a litigation list, give them the freedom to make sensible business decisions based on trust with prospects. (Who doesn’t have a litigation list? Even a perfect company would. Come on. Can you imagine if financial institutions had to do that.) Specific average income disclosure is already required and provided to all prospects. We use the SA4400 document and also Quixtar-approved business plan literature with income averages. Instead of requiring financial substantiation, accept that the buyer has a mind and responsibility for his decisions. Trust in the long-run will always secure a relationship. Let prospects be wise on their own accord. Don’t make our business practice un-fun with this strict requirement. Yuck! We recommend you find other avenues than what has been initially proposed in order to aid the integrity of individuals in the industry without harming the basic foundation of a team—trust. Bottom line for us will always be to get better at making it LONG TERM and not waste of our time. We realize that is not the case with everyone. Please don’t regulate us to a degree like the lending industry. We want to operate our business on relationships not bureaucracy. Thank you for asking for input on this significant ruling.