| Comment Number: | 522418-06260 |
| Received: | 7/5/2006 8:05:48 PM |
| Organization: | |
| Commenter: | Scott McClannahan |
| State: | GA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern: I am writing to express my concerns regarding this proposed ruling for IBOs. I have been a Quixtar IBO for about 5 years and I feel that these new rulings would drastically affect our business. I do however, support laws / rulings which would make it harder for illegal businesses and piramid scams to exist, however, it has been my experience that the Quixtar model is anything but. One of your requirements is the REQUIREMENT TO PROVIDE REFERENCES. From my personal experience, I do not believe this to be necessary. In addition, I feel that it is an infringement on our rights as a competitive business owner, as well as my personal privacy. When I first became an IBO, I was invited out to what is called a 'private seminar'. At this business meeting, I had the opportunity to meet not only the people who I would be working with, but also several others who would had been working with my sponsor. From this meeting, I was able to see that the Quixtar business was much more than an income opportunity for myself and my family. In addition to our Quixtar business, I also own a traditional business. This requirment would be like being required to provide references to my competition! Not only is this unfair to the other IBOs who may not want their information disclosed, it is also unfair to my business because the IBO could easily 'snag' my prospect. Another issue that i have is the REQUIREMENT TO PROVIDE "SUBSTANTIAL" EARNINGS and FINANCIAL INFORMATION. Again, I feel that this is not only a detriment to my business, but also an infringement to my personal privacy. Currently we provide our prospects with an extremely conservative business 'model' which is exactly that - a model. I explain to every prospect that if they do not work, they do not make money. On the flip side, they should also understand what the income potential really is, so I like to provide them with several 'real-life' examples. In addition, some of the higher paid IBOs have provided copies of their personal bonus checks, AT THEIR OWN WILL. If I was forced to provide a prospect with information on what I personally made, it would be like asking my hiring manager what to disclose what he made to every possible employee, client, vendor, etc. related to our business. Not only is it no one's business, but the success of a business model should not be judged on what one person is able to make. You don't go into an engineering college and ask every graduate what they made in their profession; so why ask IBO's to provide this information to potential prospects. Finally, perhaps the most troublesome requirement is the one to provide a "LITIGATION LIST". While I can understand the value of having such information as a prospect, I can see a far greater potential of 'misinformation' and 'false cases' being brought up. Again, in the 'real world' I'm not required to provide my 'prospective clients' with information on every lawsuit that has ever been brought against me or my employees. The prospect is free to do their own research; you can pull credit reports and/or D/B business reports; if a prosepect wishes to obtain this information, it is available, but don't make us disclose this on our own - especially FALSE and MISLEADING information about other IBOs which we have NO CONTROL OVER. In summary, I am in favor of stricter laws regarding these types of business, but I feel the FTC should focus on putting the illegal business out (btw, they probably won't obey these laws anyway); not making it harder for legitimate ones to exist and do business. Sincerly, Scott McClannahan Quixtar Independant Business Owner (IBO)