|Received:||7/11/2006 5:46:45 PM|
|Organization:||Global Net and Quixtar|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been associated with Quixtar for the past five years. Quixtar is an honest business and has always acted with the utmost integrity. When the opportunity was presented to me, I was given more than adequate information about the business and what would be required to succeed. At no time were false guarantees of easy success made. The corporation provides balanced projections of average earnings and I have found my personal experience to mirror closely those projections. I have concerns about the proposed rule for direct selling companies that the FTC is currently considering. The portion concerning that all prospects would have to wait seven days before they could register is a problem. In today's busy world it is difficult enough for two people to find opportunities to meet without the burden of then requiring a waiting period of seven days before they could register. This rule is unnecessary for a company like Quixtar because the corporation allows anyone who wishes to quit, to do so at anytime and receive a refund of their signing costs, excluding product unless the product is returned as well. Please do not mandate an additional seven day waiting period in the process. It will only complicate things for legitimate organizations. A more meaningful rule would be one that requires all companies to refund registration costs for unsatisfied prospects. The requirement for prospects to be given a list of references with detailed information is an infringement of the privacy rights of those individuals. Considering some of the characters I have shown this business opportunity to, in hindsight, the prospect should have to provide references as to their integrity and trustworthiness. This type of business does not work when a person is tricked or coerced. The relationship with a group of people is part of the appeal and detailed information on paper would be of less value than a face-to-face meeting with the people involved. I would not feel comfortable giving explicit information about my friends to someone who has not proven their trustworthiness. The portion concerning litigation is interesting. In this country people are allowed to use the justice system to make false claims. Often people file harassment lawsuits in the hope of having a monetary settlement to avoid the costs or negative publicity a trial would require. Is this a can of worms we really want to open? Look at how Wendy's was hurt by the false finger claim. I do not see how providing a record of all litigation would be helpful when the worthiness of a claim is not proven simply because the proper paperwork was filed. Finally, I have problems with the disclosures for every income claim. The Global Net materials that I use to explain the income opportunities to prospects have already been approved by lawyers, the corporation, and I believe the FTC. There are no inflated claims, instead they are lowballed so that there are no false expectations. When a prospect registers on the computer, there is already a disclosure regarding the average monthly gross income for active IBOs. I am confused by what you mean by having to provide personal financial documents to prospects. I would be happy to show how my Quixtar income has increased substantially since I began participating, but I think this should be on a discretionary basis, not mandatory. applaud you in your efforts to keep the integrity of the direct selling industry in tact, but I hope you do not institute rules which will handicap actual legitimate businesses. The most greivous would be the seven day waiting period.