|Received:||7/11/2006 6:36:04 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I feel your proposed ruling is very needful. It is obvious that some prospective buyers can be easily taken advantage of. However, I personally feel it is more of a detriment to those franchises that offer legitimate opportunities, for example: 1) Quixtar offers a very reasonable refund period for anyone wanting their investment back (no need for 7 day waiting period). 2) When registering a prospect it is difficult for some IBO's to obtain "personal information" from 10 IBO's. Quixtar partners with well over 100 recognized legitimate businesses. This shows the credibility of the franchise. 3) Supplying the prospect with a list of litigations against the franchise and franchisees will inadvertently harm a legitimate business. False accusations could lead to someone formulating an erroneous view of the franchise. Any substantiated claims against the corporation only should be disclosed if asked. 4) It is difficult in an independently owned franchise to disclose with accuracy what levels of income are present. A model should be used with a disclaimer to the fact if a person performed as prescribed could reach certain "levels' of income. A pie chart could represent those percentages that have attained these levels. One of the truisms in multilevel marketing is not all people will contribute the time and effort to attain certain levels...this is the right they have as independent business owners. Quixtar's business model clearly states that fact, yet it shows what must be accomplished to obtain each income level. 5) Providing personal income records to any prospect (interested or curious) is unfair to the IBO. If called upon by a federal or state agency so that agency can have a degree of certainty that the business is legitimate, so be it. A prospect will not discern the effort needed to obtain certain levels of income until they are educated (inside the business) as to what they are willing to do to reach those levels. Finally, I am no where near making the income I want to make in this business. Yet I PERSONALLY know first-hand the legitimacy and viability of this opportunity. I have enjoyed NOTHING less than full disclosure from my sponsor and the corporation. I realize that the success of my business lies with my effort. I applaud your concern and readiness to protect the public from unscrupulous ventures, but do not make it unduly difficult for honest opportunities (such as Quixtar) to open doors to the masses so they can make a better life. Thank you for your time.