|Received:||7/10/2006 12:15:38 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been in Quixtar for over 20 years. I feel it is the best business opportunity available. I believe the Quixtar company and its leadership is exemplary in its standards and ethics. My living is from Quixtar. Problem 1: Prospects would have to wait 7 days after receiving disclosures before they could register. When I registered I knew I was looking for something more. I was looking for an opportunity to work for myself and associate with a success minded individuals. Any waiting period would have been a serious irritation. I was ready to act now, not in a week. What I saw was an opportunity without risk. where I could get my full investment back if I wasn’t satisfied with my decision. Presenting the Business I give the Quixtar Business Plan and explain this is a 2 to 5 yr program. I show average income was $118 for 2005 as boldly printed throughout the Business Plan as well as on the registration information. Solution: Boldly state that all registration money will be refunded if requested, unconditionally Problem 2: Be required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other IBOs …. When I started I did not want people to know I had another business. I had many friends in town, in church and in social contact to whom I was not intending to present the business. The last thing I wanted was for them to hear from someone else that “Layton was in another business venture.” I consulted with many professional people who joined me in business. They also did not want their patients to know they were involved in a business outside of their dental practice. These professionals as well as I, do not want to have our name, phone number, address, etc given indiscriminately to anyone without our approval and definitely not my income given to some person just because he is a business prospect. Besides, there are some people who might just switch to join with one of the people listed on the disclosure sheet because they know them vs. me. Solution: Eliminate the requirement to provide list of other IBO’s. Problem 3: You would have to give every prospect a list of all lawsuits, etc. for the past 10 years involving Quixtar or its IBOs …. regardless of whether or not the accusation was true. Disclosing lawsuits, arbitrations or other legal claims for the last 10 years is wrong. For a business venture of $45 and the promise to get all of my money back is more important than to know Joe Blow, who can sue anyone for anything, sued the company. If it is detrimental or illegal it will make the news then our legal department will handle it and “60 Minutes” will broadcast it. Also, what foolish thing someone in California does is not what I do. Since I work for myself I should not be penalized for what someone else does. Solution: Eliminate the requirement to disclose past litigation. Problem 4: You would have to make a different disclosure for every income claim. Quixtar has SA 4400 which covers this and is in all literature. It boldly states the “average income is…. That is emphatic no matter what I say. More important, I am not looking for an employee who wants a promised income. I want him to be ambitious with out an income ceiling. The business Plan works. Solution: If disclosures are needed, require a simple, standard, easily understood disclosure such as average monthly gross income for 'active' IBOs. Problem 5: Required to provide prospects personal financial documents to substantiate any income claim. Reference number 4. What I make is confidential. The prospect should receive official literature showing income at each level. This is a 2 to 5 year plan. Not like other franchises where you have tremendous financial obligations to face every month just to keep a business afloat. Here I just furnish gas, phone and computer upkeep. Solution: IBO’s should have proper documentation to show averages and income generated from each area.