Comment Number: 522418-07699
Received: 7/11/2006 2:42:45 PM
Organization:
Commenter: Demark
State: WI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear Commission, My wife and I have been IBO's powered by Quixtar for 1 1/2 years. We understand that the FTC wishes to ensure that every prospect considering a business opportunity has all the information he or she needs to make an educated decision. We applaud this goal. As we personally share this business opportunity, we have always been committed to providing prospects with complete and accurate information about our opportunity, so we fully support reasonable and responsible rules to help manage the expectations of prospects. We build our business with integrity and honesty and qualify our prospects by using the same standard. However, the newly proposed rule on "Trade Regulation Rule on Business Opportunities" raises some concerns: First, we would ask that you eliminate the proposed waiting period before a prospect can register as a business owner. As IBO's powered by Quixtar, my wife and I always engage in a 3 step process to see if the prospect qualifies to work with our business team. In that process, we make sure that they receive the necessary information to make an educated decision. Also, Quixtar has a money back guarantee if the prospect is not satisfied. Second, we would ask that you eliminate the requirement to provide 10 references. This requirement infringes on our privacy as a couple. We do not want our names, address and phone number given out to any and all prospects in this area. Also, what would stop another IBO from taking advantage of all our hard work by registering our prospect in their business? Third, we would ask that you eliminate the requirement to disclose past litigation. The fact that many lawsuits are build off of alleged fraud, misrepresentation or unfair trade practices regardless of the truth of the accusation would open Quixtar and our business up to false accusations. Fourth, we would ask that if disclosures are needed, that you require a simple, standard, easily understood disclosure instead of a different disclosure for every income claim. Quixtar already clearly indicates on all their literature an easily understood disclosure about the average monthly gross income for active IBO's. My wife and I always point that out in the process as well because it helps us qualify those that are curious versus those that are serious about building a solid business. Finally, we believe that IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. My wife and I have found that the benefits to building a business powered by Quixtar are beyond financial. We have personally benefited from the association with other successful IBO's, from the principles learned and applied through books we have read and from the positive changes in our marriage and in our family. We applaud the heart behind the proposed rule change, but we trust that you will consider these changes. Sincerely, Mr. and Mrs. Demark