| Comment Number: | 522418-07399 |
| Received: | 7/10/2006 6:46:41 PM |
| Organization: | Quixtar |
| Commenter: | Ken Woods |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir/Ma'am, I am writing this letter as a response to the recently proposed Business Opportunity Rule. My wife and I have been Quixtar IBOs (Independent Business Owners) since the company began in 1999. We were recently informed of the proposed rules through the Quixtar corporation. In reviewing the proposed rules there are several areas that I believe would negatively impact my business. I appreciate the opportunity to comment on some aspects of the rules that would dramatically affect my business. Let me begin by saying that your goal of eliminating fraudulent so-called business opportunities is important to me as well. Fraudulent get-rich-quick and illegal pyramid schemes give legitimate businesses, such as the Quixtar business, a bad reputation and cause potential IBOs when they are presented with this legitimate opportunity to shy away. I believe that when people have the opportunity to review any business they need to have a full view of the business they are reviewing. This is exactly how we do business now -- already! If other companies would simply bring their business ethics to a point where there was more disclosure, like with the Quixtar business, there would not be so many issues. I do not believe it is appropriate to place too high a level of burdensome restrictions on companies that are already responsible in the way they do business. Please work with our trade organizations such as the Quixtar Independent Business Owners Association or the Direct Selling Association in order to develop reasonable standards for all businesses. Quite frankly there are already best business practices available for review that would negate the need for such restrictions like the 7 day waiting period, lawsuit disclosures, need for references, or drop out/ cancellation rates. These highly intrusive business restrictions, which in my opinion sound reasonable to someone who is not familiar with our business, are quite simply unenforceable measures that are overly burdensome and would scare people away from my legitimate home based business that are completely built on the "Golden rule" and personal relationships. I am speaking as an IBO who does this part time and only makes between $200 and $400 a month from this business. For me and my wife, with two children (5 and 7), this is worth it -- but not if the business is going to become so difficult to build. As a humble suggestion, I would like to encourage you to send a delgation to the Quixtar offices to review how it is that IBOs actually run our business and look at the products we sell and use. There is somewhere near 50 years of experience in the industry with our parent company Alticor. Its subsidiary Quixtar has a "Rules of Conduct" for all IBOs which is very extensive and explains in detail the responsibilities of an IBO, we also have all of our advertising and training materials "Content Reviewed" by Quixtar to ensure that we are compliant with the FTC as well as other more restrcitive state laws in various states. We have binding arbitration agreements, and a money back guarentee for our products and services -- we are already working on improving the way we do business on our own. Please work with us and enforce the laws you already have at your disposal as opposed to making new rules/laws. The Quixtar corportation has even begun to build an "Accreditation Program", which is similar to a 5 star standard or Gold Seal of approval to ensure that we are building our businesses in an ethical way. Please do not create arbitrary rules that will regulate our industry, when there are problems that can be handled by enforcing existing rules and working with the "legitimate" companies, such as the multibillion dollar/multi year -- Quixtar corporation. A company with legitimate products and services that have a money back guarantee. Thank you for your time and good luck, Ken Woods Quixtar IBO# 1342281