|Received:||7/11/2006 8:25:37 PM|
|Organization:||Quixtar: IBO #2723429|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:We became independent business owners in the Amway business and now in Quixtar since 1995. During this time we developed a small group and have primarily used our membership to sell products directly to consumers while using the products and services. There has been a consistant monthly income, access to my favorite products, many with a 100% money-back guarantee, help and communication with very positive business people, as well as the convenience of shopping online with delivery to my home. The seven-day waiting period after receiving disclosures serves no advantage with businesses like Quixtar. A person can get their money back in the first 30 days if there is a wish to leave the business. This lets those who want to get started to do just that, while allowing those who want to leave the business to do that with return of their invested money, and they have 30 days from the day they sign-up to do it. Ten references provided to prospects infringes on the privacy of other IBOs who would be listed. When the business information is provided, the people in our line of sponsorship have always been available and willing to meet and assist with any questions and quidance requested. Likewise, I would not want my name simply put on a list described in the proposed rule. A list of past litigation, lawsuits, arbitrations and other legal claims is offering a bias to unresolved issues, opening one-sided opinions in many cases and not fact nor general practice. So often this can disclose an isolated problem and seldom, if ever will disclose the solution to problems and/or issues proven wrong or solved. Quixtar provides the average monthly gross income for active IBOs multiple times during presentations, on the website and approved literature. This is a standard that can be understood easily. They also describe what they refer to as an 'active IBO', so the income is not misrepresented. This seems a fair, open, uncomplicated and straight-forward disclosure. Personal financial records can be easily altered from reality and may provide an unrealistic expectation of the prospect for those who have achieved a substantial income. It may also be unfair to the IBO who has not been in the business very long or is just starting to expand their business. We have never been told of quick money or not having to work hard for a good income from this business. By the same token, we explain to prospects that money is earned with concentrated work. We received assistance and offer assistance to those in our group. Forming rules that restrict those who are less than honest while not restricting those who have done a good, honest job in the direct sales industry of network marketing is necessary and challenging. We hope this has been a help toward your efforts.