|Received:||7/12/2006 4:43:32 PM|
|Organization:||Schaeffer Unlimited Inc|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO for 16 years, reached the Emerald level, and have been able to replace my wife’s income and my Air Force income as well. Quixtar was a perfect fit into my lifestyle as a US Air Force pilot. My schedule was up in the air and many times, I was gone for weeks at a time. This business gave me the flexibility to work when I was home on my own terms and schedule. It also continued to grow in the times I was deployed. The other benefits outside of income are a sense of community with fellow IBOs, strong family values, and recognition beyond the Air Force. Even before I was registered, I was provided with information (written and recorded) to answer questions, and to help me map out a game plan to start my business. I also had the opportunity to ask questions of the people who had explained the opportunity to me. I believe it was enough to make an effective decision and the startup cost was nominal compared to the other businesses I had investigated. I strive to help people make informed decisions regarding this opportunity using fair, balanced, credible sources. When I show this business plan, I emphasize that this will take work, it won’t jump up and give you income for nothing, and that effort is required. To register, I usually start IBOs without the product pack because I give them samples of just about everything that is in there. The startup cost is around $62. I feel the proposed changes will have the following effects: 7 day waiting period – Due to my schedule, this would mean scheduling another followup meeting to help get registered seven days later. When I was home for a few days, this would mean I couldn’t help them develop their business before I was gone again and they may have to wait for my help for weeks sometimes. Due to the very low startup costs, the fact that inventory can be returned, I don’t see any benefits in a 7 day waiting period beyond what is available now. There are different rates of business growth as well. Some businesses grow faster than others and this would significantly hinder efforts to grow those businesses. Requirement for references: This is fine if you are a business that requires a specific skill – ie mason work, carpeting, landscaping – but for our business, we pride ourselves in the fact that anyone can build a business if they have the will to. When you look for references, there are other systems, personalities, and many risks that we would have no control over. Also, as a military member, if I just changed my station, I would not have anyone to refer as I would be new to the area. You would then be limiting your business to only established individuals. I feel prospects have that opportunity to meet with other at our conferences, seminars, team meetings, etc. and to supply them also takes the time and delays their growth. Litigation List: Providing a list of all litigation would severely handcuff our growth. There is enough free information out there versus having to provide litigation (even unmerited) to a prospect. I feel that would not represent me or my family’s experience with this business and therefore would put only negative questions into a prospect’s mind. Specific earnings disclosures and financial substantiation – I don’t disclose income unless it is outlined in the SA-4400 and follow those numbers. My own experience is that even disclosing income, there are other factors, real estate losses/gains, charitable giving, other income sources that are confidential and should be kept so.