| Comment Number: | 522418-06308 |
| Received: | 7/5/2006 10:44:55 PM |
| Organization: | WorldWide Group |
| Commenter: | James Porter |
| State: | MT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been an IBO with an affiliation with WorldWide Group out of Spokane Washington, since the summer of 1995. My intent it to continue to expand the business to assist others and provide needed retirement income for the future. I have always found my upline and WorlWide group as a whole to have outstanding integrity. Their projections of what could be with this business has always been understated and they always conveyed that it would take a consistent effort to be successful. We have always utilized our SA4400 when presenting the business plan to prospects, which uses a conservative statement governed by the FTC saying that the average active IBO earns $115.00 per month. We have always encouraged them to do their due dilegence and to check with the BBB, the state auditor's office and other independant sources before making a decision. Since we have always offered a 6 month money back guarantee, i see no need to any waiting periods. We have never had to issue a refund either. Due to privacy considerations, I would not want to be providing references any more than I would in any business. One the subject of discolosing past litigations; no business should be required to do that, especially in a legal climate such as ours when many lawsuits can be brought without charge by the claimant and many of which are proven to be frivelous and unwarranted. WorldWide group has always been very fair in their pricing structure regarding tapes, books and functions. Many of their test sites for functions are funded at a loss by the Speaker. If they are making a "reasonable" profit, of which they are entitled, thank God. They need to make a reasonable profit to stay in business and assist the IBO's in obtaining their personal goals with the business. $2.50 for a CD, and $7.00 to attend a key speaker function is incredibly fair. I personally work with a Fortune 500 company already and what we are currently providing to the prospect by Worldwide Group, it. the SA4400 document and our plan material, far surpasses what the insurance industry (outside of investments or variable product) has to provide. I think the material we are using with WorldWide Group is very well done. We can't over regulate something like this, but we can require certain disclosures regarding how the business model works, which we do. Disclosure of one's earnings to a prospect is probably never a good idea anyway and I feel it should be withheld in most instances unless needed for an investigation of some type. Therefore I am against providing that information to a prospect, period. Besides what is a good earning figure for one is meaningless to another and it is very difficult to take a promoter's earnings and put it into perspective of the prospect anyway. Again, I like what we are using: The average "active" IBO is earning $115.00. When one studies the definition we use for "Active" this is a very conservative figure to a prospect. Quixtar's Volume and Growth incentives are performance based and are clearly outlined in the SA4400 business overview. We can regulate all we want, but there are always those that will violate a trust, no matter how many restrictions we have imposed on us. It's always a result of the character of the people and the relationships and respect between people that yields that win-win situation for the prospect and the promoter. I wish you well. Yours Truly James A Porter