|Received:||7/6/2006 4:57:30 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To Whom It May Concern: I am a Quixtar IBO affiliated with Winters Marketing. I wish to register my opinion about the proposed legislation affecting direct selling business opportunities. Several of the proposed rules affect problems that I feel we (Quixtar IBOs within the tutelage of Winters Mktg) have circumvented already. My philosophy and that of my mentors is that the business will grow much faster (and with more integrity) when we sponsor excited, informed, motivated individuals who have their own desire for such an opportunity. I understand that if I coerce or misinform someone to get them registered, and they register with incomplete information or under false pretenses, more work will be required of me with a less fruitful outcome. When I show someone the plan, I explain how the income shown results from that specific business structure (6-4-2) and I explain how an individual cannot sponsor only one leg and just profit off of its growth. I inform potential business owners that should they change their mind, they may have their registration fee refunded by the corporation within 6 months of signing up. I also tell people that the product pack available at registration is optional and refundable, but it is strongly encouraged as personal use of the edible products is a benchmark on our team. After showing someone the business ownership plan, I generally spend time with them answering questions, showing the website, promoting the next educational event for Winters Mktg, and helping them make a list of potential business owners for their own expansion (if they let me I will help them repeat the sponsorship process with these people). In my business these are more important tasks than actually registering an individual on the site. Additionally, and this is taught throughout the Winters Mktg organization, we do not sponsor an individual until they have attended an opportunity meeting and met some people on the team. As for income claims, on our team we tend to promote the income of people who have achieved some success but we also hand out literature stating that the average income of "active" IBOs in the past fiscal year was $115. We also highlight the incomes of people who are very new in business and who are making between $100 and $200 in their first two months. I would feel uncomfortable disclosing my income to prospects for several reasons. First of all, through my Quixtar business I have associated with a team of mentors who have helped me do much more than sponsor people and sell products. In fact, during the past 2 years that I've been involved with Quixtar, I've gained the confidence to seek a more demanding and higher paying daytime job. I have also developed friendships with people who have a financial interest in my growth as a business and an individual; these friendships have been rewarding and have affected my personal life immeasurably. The various intangible benefits are not always appropriate to delve into with a new prospect, but are apparent within a few months of beginning one's business (well within the range of time someone may obtain a refund). I am a 2500 in the business, generally earning between $500 and $600 (I often give my customers my price and thus make little retail profit). If someone had told me when I saw the business plan for the first time that I would work as hard as I have for this amount of income after two years, I likely would not have gotten started because I would have been unable to comprehend the intangibles. Knowing what I know now, I would happily start from scratch because I understand the amazing intangible benefits. Most people will not take on a challenge if, at the start, before developing a hunger to finish the race, they are told of every obstacle they will face along the way. This sort of a business builds character cumulatively, so as it gets more challenging, each person is more equipped to handle it. Please consider the above. Thank you.