|Received:||7/11/2006 11:53:00 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear Sirs, I would like to address your proposed new "Trade Regulation Rule on Business Opportunities". While I agree with the desire on the part of the FTC to make sure that consumers have all the information they need to make a good decision about participating in a business opportunity, I feel that the proposed rule in its present form would create serious problems in the building of my Quixtar business. I have been involved in the Quixtar buiness since it began in September, 1999, and before that for twenty years with it's catalog based predecessor. Before I registered in 1979, I had the business explained to me in a home meeting. I was given several tapes, products to try, material to read, and had about two days to review the information,and to talk to the people who shared the business with me. I had adequate time and information to make the decision to register and begin to build my business. I was never given the impression that I could make money without effort, but found then and now that the income I have earned for the time and effort I have put into my business have been better in this business than the income received for effort given in other endeavors I have pursued. Other than just the income, my participation in this business has impacted every area of my life. I was single when I began building my business. I met my husband through the business. I have traveled to Hawaii, Mexico, Jamaica, the Bahamas, been on several cruises, and even to Russia. These trips have either directly resulted from my business building activities, or from contacts I made while building my business and would not have happened without my participation in this business. I am in great health due to the training and nutritional products I use that come from my business, and to the goal setting I have learned from this business. My kids have also benefited from both the products they use and the training and association they have had with our mentors in the business. Our whole family just completed the Houston Half-Marathon this past January, including my son, who is blind, and ran with a sighted-guide and we attribute our accomplishment to the habits and goal-setting we learned from our mentors in the business. As to the current proposal, I feel our business would be adversely affected by the seven day wait before registering. Many IBO's are ready to get started sooner than seven days and would be so discouraged by having to wait that they might never get started, even though they had adequate information to make an informed decision to get started. Any IBO who registers and has a change of heart can get their money back from Quixtar, and therefore has no risk associated with making an informed decision in less than seven days. The requirement to provide references could actually put myself and other IBO's at risk of having our prospects register with one of the references rather than us. Also, the requirement for other IBO's to give out my name, address, and phone number as a reference would violate my privacy. Our prospects, and those of other IBO's in our organization are encouraged to meet other IBO's at meetings and seminars to learn of their experiences in the business even before they decide to register. As to the litigation list, the propsal does not adequately cover what a "seller" is and looks as if IBO's would have to list all litigation involving Quixtar as well as the entire IBO force across the country. Also, this list is not even limited to cases found against the seller, but even to filed cases with no merit. I feel that there are problems with the specific earnings disclosures and the requirement for fincial subtantiation as well, though my space is limited to discuss those in detail. Again, I agree with the FTC's effort to make sure consumers have enought information to mak a good decision, but feel the current proposal has too many problems to be adopted as is.