|Received:||7/5/2006 11:52:08 PM|
|Commenter:||Michael P. Rutland|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am an Independent Business Owner (IBO) and have been affiliated with Quixtar for a little over six years. As a business owner I have set goals for both myself and my business and like every business owner I’ve both achieved and missed goals. For the goals I achieved there was great satisfaction and for the ones I missed I learned and moved on. When I first registered my sponsor was extremely thorough. He explained this business powered by Quixtar was not a get rich quick scheme and would take effort on my part if I was to be successful. He ensured I knew exactly everything I need to know to make an intelligent decision about my future as an IBO. Prior to signing anything or committing myself, my sponsor had me do my research. He suggested I start with the Better Business Bureau and the US Chamber of Commerce. I did my research and was both impressed and excited with what I had found I called my sponsor and immediately set a time to get started. My sponsor then introduced me to the organization that would help me with my business, the World Wide Group. He explained that I was in business for myself but not by myself. To this day I have not had any regrets. Am I at the level that I want to be? No not yet, but there is no way I will ever stop moving forward. I understand you are in the formation of establishing federal guidelines; laws if you will that will govern all direct selling opportunities. I whole-heartedly support this effort. If other direct selling opportunities had been placed under the same scrutiny that Quixtar and their parent company Alticor were there would be little need for federal intervention. That said; there are some items being proposed that cause me great concern: First is a requirement that I furnish a prospect with a list of at least 10 other IBO in the local area. This would amount to giving my prospect a shopping list to go IBO shopping and that would make me no more than a headhunter for someone else. Second, establish a 7 day waiting period after receiving disclosures before they could register? Why? For those of us associated with the World Wide Group and affiliated with Quixtar, we thoroughly explain this business up front. We leave no stone unturned in making sure that our prospects know exactly what they are getting prior to registration. Besides Quixtar has a 100% money back guarantee if not satisfied. Third, give a prospect a list of all lawsuits arbitrations, or other legal claims for the past ten years involving Quixtar of its IBOs where the plaintiff alleged fraud, misrepresentation or unfair trade practices – regardless of whether or not the accusation was true? To what extent would you require the prospecting IBO go to satisfy this requirement? You do not define “seller”. How big would the list be? Would it include the entire IBO force across the country and around the world? You might as well invite a prospect to go read a public bathroom wall. IBOs affiliated with the World Wide Group insist our prospects do there homework and completely investigate the Quixtar business opportunity prior to signing, committing, or entering into any business agreement. I know that your efforts are only in the first phase of formation. I hope you will take into consideration that those of us who are IBOs powered by Quixtar operate to a higher standard than some of our other direct selling brethren. In formulating your rules I would also hope you would take a close look at how the World Wide Group and Quixtar operates and use them as a Benchmark for other direct selling opportunities to follow. Thank you for your time.