| Comment Number: | 522418-07425 |
| Received: | 7/10/2006 8:10:59 PM |
| Organization: | |
| Commenter: | Dorothy K Austin |
| State: | MA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sir or Madam: I am an independent business owner (IBO) marketing Quixtar and affiliated products. I have been engaged in building my marketing business since February of this year. In addition to my marketing business, I am a full time employee as an engineer. The Quixtar system is enabling me to increase my income for the purposes of eliminating debt and ensuring my retirement. These are goals I am unable to meet with my employee's salary, which has been at a plateau for four years due to economic factors predominately outside of my control. The affiliation with Quixtar provides me with access to premium products of all sorts, which allows me to choose which products I would like to focus my marketing efforts on. I can't say enough about the cutting edge product research which Quixtar engages in and the tools made available to IBO's at a very low cost. Prior to engaging with Quixtar, at a nominal cost of less than $50 per year, I had researched three business opportunities. These included a retail store and two franchises. I also have prior experience marketing an industrial product at the wholesale to retail level. The opportunity provided by Quixtar, at an unbelievably low investment, is by far and away the best thing I have seen in my search for a business ownership opportunity. I applaud the FTC for attempting to weed out unscrupulous and disingenuous network marketing franchise offerings. This can only help me in my presentation of the legitimate Quixtar opportunity. However, some of the elements of the currently proposed rule are unduly burdensome to me as I present the opportunity to fellow IBO prospects. Given the fact that the affiliation fee of less than $50 is so small, and the fully refundable nature of the fee, several of the proposed requirements present undue paperwork burden and lack of privacy considering the scale of the investment. Consumers are allowed to make much bigger purchases without all of these disclosure rules. The specific elements of the proposed rule that are at issue are: - requirement of a seven day waiting period - requirement to provide references - provision of litigation list - specific earnings disclosures - financial substantition requirement For the Quixtar affiliation, due to the fully refundable nature of the fee, no waiting period is necessary. A waiting period would interfere my ability to move to a point of action with a prospect who may be ready right now to get engaged and get going. The remaining requirements, for documentation, will not provide more information than is already faithfully presented by the IBO's and will make a substantial bureaucratic burden for a small, low overhead business like mine to support. It is already a challenge to make the time to conduct all of the business activities that are necessary without the added burden of significant red tape. Remember, this is a voluntary business that is typically conducted out of a home in spare time available outside of a full time job. Thank you for reviewing my comments. I trust they will be helpful for your decision making. I look forward to the elimination of illegitimate business that can give network marketing a bad name. Sincerely, Dorothy K. Austin