|Received:||7/10/2006 12:26:51 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am a Widow who has been a Quixtar Independent Business Owner since 1999. Prior to Quixtar, I was an Amway Distributor having started my Amway business in the 70s. Thus I have over 30 years experience in business. Diamond is my highest level of achievement. I have read the proposed FTC Business Opportunity Rule, R511993 and totally agree that there should be industry-wide, uniform disclosure requirements for all business opportunities. However, I question if those intent on deception and selling bogus business opportunities would follow the new rules, if adopted. Yet, some of these proposed new rules would impose an un-necessary burden on legitimate business opportunities such as Quixtar.. For instance, the rule to wait seven days after receiving disclosures before a prospective IBO could register would greatly impede a new IBO in successfully launching their business. When I started my business, I checked out the business with the Better Business Bureau, The Chamber of Commerce. I sampled the products and read the disclosure statements about the business opportunity provided by my Sponsor and Mentor. I received adequate information to do my own due diligence and feel that an arbitrary waiting period would be detrimental to the business as a whole. Also, it would negatively impact the business of the more established IBO. Quixtar does not require a major investment to begin a business and the registration fees and any product samples purchased has a money back guarantee; therefore, there is no risk to the new prospect should they register the first night However, what this proposed new rule would do is the exact opposite of the intent. It would not protect the new prospective business owner it would impede his/her ability to successfully launch their business by making it almost impossible to establish momentum; therefore the waiting period for opportunities like Quixtar (where a prospect can get his/her money back) should be eliminated Second, I have been in business for 30 + years. I would not want to give my “prospect” that I had invested my time, my resources, energy, ability into the names of 10 competitor IBOs in my area – seven days before my prospect could register. That would be like McDonald’s telling a customer before they could buy a hamburger to go down and talk to Burger King and vice versa. Prospects have ways to check out honest business opportunities via the Better Business Bureau and the Chamber of Commerce. This should not be a requirement and should be eliminated. We live in a litigious society where lawsuits are filed with no merit by unscrupulous individuals simply to get settlements from companies and individuals that prefer to settle rather than get into a long drawn out expensive litigation. To require a list of all lawsuits, arbitrations, and legal claims for the past 10 years involving Quixtar and its IBOs where alleged fraud, misrepresentations, or unfair trade practices (regardless of the truth)…would probably by an impossible feat due to the size and scope of the Business. Most important our competition could use this requirement as a way of creating an unfair advantage by filing frivolous lawsuits to jam up the flow of doing business. Please eliminate this requirement. The income disclosure of personal financial documents is an invasion of privacy. Income goals are individual private matters. A simple, standard, easily understood disclosure about the potential and the statement of “average monthly gross income for ‘active’ IBOs” should suffice. Giving “text book examples” of what is possible in sales and marketing as it pertains to income potential does not guarantee or imply that is what everyone earns but rather what is possible with diligence, hard work, and persistent effort over time. With Quixtar we provide prospective IBOs with extensive information before they register and ongoing support, education, training and assistance after they register.