| Comment Number: | 522418-07314 |
| Received: | 7/10/2006 1:19:26 PM |
| Organization: | Quixtar IBO |
| Commenter: | Jeff Castina |
| State: | NC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am in definite support of the general purpose of this proposal, however I do not agree with the provisions requiring a waiting period, business owner references, or financial statements in support of income estimates. First, I don't see the advantage of the waiting period, especially since our servicing company, Quixtar, gives new Independent Business Owners (IBOs) a 100% money back policy for "un-registering" for up to a full year. Regarding the references, we have weekly Open meetings in nearly every city and large town that allow any individual the opportunity to come and meet many local IBOs before they decide to register...but if a prospect is not interested in getting references or doesn't ask for the references, why should it be mandatory to maintain a list of local IBOs willing to take phone calls from prospects? Also, when we are trying to start a person in a remote place or new city, we wouldn't even necessarily know 10 other people who are already there. And, not knowing the individual effort that a person has put into their business, I would not feel comfortable in giving them as a reference to a prospect unless I knew their business, work ethic, and attitude. Lastly, sad to say that some could do it, but allowing my propect to contact up to 10 other IBOs before deciding to register, could result in them registering with another IBO. It is the equivalent of a mechanic having to give each potential customer the names & numbers of 10 other local mechanics before being allowed to work on someone's car. It is NOT like asking a mechanic to provide the name of 10 other customers in the area. On that note, for a fairly new IBO, they don't yet have 10 non-competitive IBOs to offer as references.