|Received:||7/12/2006 12:14:55 PM|
|Organization:||HDT Consultants Int''l Inc|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been IBOs since January 1994. We pursue the business full time, since we have repalced our incomes from both former jobs.We now have time to schedule our lives as we see fit. So we travel a lot and enjoy spending a lot of quality time together. When we registered, we got the FTC approved SA 4400 and other literature about the company, the products. This was in fact more than enough information to make an informed decision. We also had the benefit of associating at various traninig meetings with several other IBOs from whom we obtained information of their experiences in the business. When we sponsor someone, we afford them the same treatment we got, emphasising that this was a true business, that you get out ahat you put in, that it wasn't something for nothing, that there were no guarantees, but that success would probably come from working diligently on a consistent basis and having a long-term view of the business. This is routinely explained to our prospects up front in 2-3 meetings before the register formally. The registration fees is about $150 including shipping and handling and tax. There is a optional training package for $95 which is refundable in 120 days. The Quixtar registration fees is refundable for up to a year after initial registration. Currently the new IBO registration time is based on when their money is available. Sometimes it's minutes after seeing the presentation, sometimes it's months. There is no exposure if there is a 100% money back guarantee as we currenly have.Waiting 7 days would be highly counter- productive, especially where the new IBO also have other prospects waiting to get started. This happens a lot.The 7 day waiting period would severely retard business. A new IBO has at least 3 times per week at various team gatherings to poll other existing IBOs about their experiences in the business. There is a lot of opportunities for association with other IBOs who do not have a vested interested in the prospect or new IBO success. Hence the views elicited from them are likely to be more objective. This is more effective than providing references of people whom they may never see again. Besides, there would also be the requirement to ask for permission of the persons whose contact information is going to be shared with the prospect. Providing a litigation list would be a big burden. The list would prove nothing, given that in this litigious society, almost all organizations have been sued. It is better to encourage the prospect to check with the Better Business Bureaus and States Attorneys General. Enough specific earnings are already provided in the SA-4400 as well as average monthly gross income per IBO. It would be unwieldy to provide separate disclosure for every example used in a presentation to illustrate income potential. No one knows what the prospect's commitment is going to be in working hard to achieve their goals and dreams. Specific earnings would apply only to the specific business to which it relates and would only hold if the prospect develops the same business. Financial substantiation about personal income is private and providing this to the propspect would seem to guarantee them the same kind of income without knowing whether they are guaranteeing the same effort that we put in to get to any laevel in the business. We emphasise the lifestyle that the businesss has afforded us, as there are other attributes to the business outside of just the income generated. Having many people have our financial records seem a bit inappropriate and probably a little risky given what is currently being done with identity theft etc. Our practice is to stay within the guidelines approved by the FTC in the SA-4400 as we think there is enough income shown as being achievable there. There is no need to embellish any other income potential. This is a true business opportunity. It takes WORK!!!