| Comment Number: | 522418-06993 |
| Received: | 7/8/2006 1:08:54 PM |
| Organization: | |
| Commenter: | amitabh parasher |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My Wife and I have been Quixtar IBO's for approximately 5.5 years. As a result of our part time efforts we had attained the level of Platinum IBO 3 years ago which has allowed us to have a reliable secondary income to provide security for us and our 2 small boys. Our next goal is to attain the Emerald level which can allow My wife to stay home and be a full time mom to our children. Through the education and support we have been introduced to positive and inspirational guidance across life topics including having quality relationships, time management, goal setting, positive mental attitude, self-confidence and dedication to service. Before we were sponsored into this opportunity we were given all the information needed to make an informed decision.We are taught a standard method of giving information to prospects so they receive the same quality of information before they join. We inform our prospects of the investment in time and money that we commit, and that our success does not guarantee their success. Our prospects also have the opportunity to attend an Open meeting at the local Ramada Hotel before they enroll so that they may see several hundred other IBO's in the area many of which which share their own Quixtar experiences every week. Our prospects spend approximately $73 to register their business along with some Quixtar materials and are offered an optional product intro pack and education and support kit for a maximum of approximately $230. We also inform each prospect that they have 90 days to try the business and if they are not satisfied we will refund the money(minus $7) they spent which is either credited back to our card or the ex-IBO's card. The seven day waiting period in the FTC proposal would hurt our business. Adequate information is already provided before registration and we provide the 90 day money guarantee. A waiting period will diminish this opportunity because a new IBO would now have to wait longer to produce a profit. Today an IBO can register as many IBO and customers their first or second week and see significant sales and profit within the first 30 days. The seven day waiting greatly reduces the profits for all subsequent IBO's the lines of sponsorship. Also if I register a new IBO in another state I now have incur twice the travel costs between showing the opportunity one week and returning to register the following week. This will make many long distance prospects financially unfeasible to register. Providing the contact information of local IBO's as references is a violation of our privacy as we operate home based businesses and are not open to visits or calls by strangers at our homes. We live in a large metropolitan area where thousands of prospects are attracted to the opportunity which are not people to whom we wish provide our personal contact information. Also there is nothing preventing the risk of another reference IBO attempting to sponsor our prospects. As far as providing a ligitation list the proposal does not clarify who is a seller. It will increase the hardship of each new IBO we register who operating their business on part time basis alongside a job would need to list, carry and present the ligitation list of Quixtar, its employees and hundreds of thousands of IBO's each time they market the business. This will reduce sales and profits. A significant percentage of this litigation may also be cases filed but with no merit. Regarding earning disclosures and financial substantiation, our literature pack given to all prospects after seeing the opportunity contains the printed SA-4400 and average monthly gross income. This contains all the details for qualifying for a significant (Diamond) income level. We inform prospects that our results and income are due to our personal competency and not any guarantee. Our income is uncorrelated to theirs. The prospect may lag or greatly surpass our results based on their own competency and resourcefulnes