| Comment Number: | 522418-08454 |
| Received: | 7/12/2006 8:41:17 PM |
| Organization: | Angell Enterprises |
| Commenter: | Thomas Angell |
| State: | MN |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife and I have recently begun actively building a business utilizing the Quixtar business. This business opportunity offers us a chance to supplement our retirement to the point where we will be able to live with financial dignity. Without it, we will be unable to retire and must continue working until we are no longer physically able to do so. We were provided ample information from the Worldwide Dreambuilders organization and from Quixtar; this clearly indicates this is not a get rich quick scheme. We provide the same information to our prospects. Prospects typically invest about $150 for registration fees and optional product pack materials; this is refundable should they decide to leave the business. 1. Re: the proposal for a seven day waiting period: we feel no purpose would be served because the prospect's fees are refunded if not satisfied. We feel that the seven day waiting period would have a chilling effect on the growth of our business and on the growth of our prospect's businesses. 2. Re: reference requirement: We feel that this is an invasion of our privacy to let other IBO's give our name, address and phone number to their prospects. If we had to provide such a list to our prospects, we feel there is a risk they might register with someone else. This almost happened with one of our prospects, even without this requirement. Our prospects are invited to information briefings and have a chance to meet other IBO's. They are encouraged to freely discuss with other IBO's their experiences. 3. Re: Earnings disclosures: We inform prospects of the income potential according to the information contained in the SA-4400. Since this information has already been approved, we do not feel that additional detail would serve any purpose and would become unduly burdensome. 4. Re: Personal Financial Information: We provide prospects with a verbal statement regarding the bonus amount that we received for the previous month. We feel that being required to provide a detailed financial statement would be an invasion of our privacy and therefore inappropriate. In summary, we suppport the idea of creating a level playing field applying to direct sellers. Income disclosures should be simple and standardized. There should be a reasonable policy regarding cancellations. There should NOT be a waiting period requirement. Financial records should not be disclosed to prospects and there should be no requirement for providing IBO references. We thank you for the opportunity to comment on this proposed rule. Sincerely, Thomas A. and Nadine G. Angell