Comment Number: 522418-06085
Received: 7/5/2006 11:45:31 AM
Organization: Quixtar & LTD Leadership Team Development
Commenter: David Vics
State: OH
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I have been involved in the Quixtar business for almost 16 years. I met my wife in the business, and most of our lasting friendships with people are part of our organization, or people we service as customers. Without the Quixtar business and association with the leadership of the LTD organization, I would be pursuing the corporate jungle. Our life today is completely different due to the values of family, freedom, reward and responsibility I've learned from being an Independent Business Owner (IBO). My hope is that our children follow in our footsteps, and choose to build a Quixtar business along with us, so we can enjoy time with together with our family and live a life of purpose and reward. Regarding the proposed rule changes, I understand that there are a lot of fly-by-night operations out there. The here-today, gone-tomorrow MLM's, grab the cash before the organization collapses business models are certainly in need of some tighter control. I admire what the FTC is trying to accomplish by helping to clean up this industry from abuse, and restore respect to the ranks of honest and industrious IBO's. In response to the proposed changes: Issue 1: Waiting period. We have a 100% money back guarantee on startup costs, products, and business and support materials. All other companies should have the same. If someone wants to get started right away, they should have that right. They should also have the right to change their mind later. Money back guarantees minimize risk while maximizing efficiencies. Issue 2: List of references. I have an independent business. My clients, and other IBO's I serve is not public information. Unfortunately, lists have a tendency to be abused in today's information hungry, privacy lean culture. Our approach is for people to associate with our leadership, and talk to people that they meet at our meetings and seminars. I wasn't given a list of referrals when I hired onto my job, and other businesses opportunities aren't required to do that either. Without financial risk (remember the money back thing), this rule doesn't make much sense. Issue 3: List of lawsuits - We don't have enough paper in the United States for that, nor does this rule make any sense. Our country is a lawsuit-happy place, and just because you are sued, it doesn't imply anything. This would make it very simple for LAWYERS.INC to file suits just to discourage people. If people are really that curious, they can research case law, which is public information. Providing a list of lawsuits? I don't remember seeing one of those when I hired onto my job either. Issue 4: Income claim disclosure: We already provide that. FTC may want to standardize income claims within the industry for "average" IBO's, "active" IBO's, and "IBO's who've sponsored at least 2 people". Or something along those lines. People need to be aware that a lot of people sign up but don't do anything. The average income numbers need to reflect that, but also reflect incomes that REAL IBO's make, based on performance or level. Issue 5: Personal financial documents: My personal finances are nobodies business but mine and the IRS. People should be required to state if their purchases are from income made in the business, and held to that. Or they should be made to say if their lifestyle is from Business Support Material profits or from other sources. But providing my 1099 or my profit sheet to someone is not something I feel comfortable with. Plus, we already make available copies of Performance Bonus checks when peak earning months come around. People usually extrapolate the peak months, and tend to believe that max earning months are every month. So providing copies of earnings are easily manipulatable.