|Received:||7/12/2006 9:19:14 PM|
|Organization:||TEAM / Quixtar|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To Whom It May Concern, I would like to comment on some of the proposed regulations for Business Owner Prospects. Problem 1: Prospects would have to wait seven days after receiving disclosures before they could register. Solution: Eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied. Problem 2: You would be required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other IBOs in the area – seven days before the prospect registers. Solution: Eliminate the requirement to provide 10 references. This could also violate the privacy act. Problem 3: You would have to give every prospect a list of all lawsuits, arbitrations, and other legal claims for the past 10 years involving Quixtar and its IBOs where the plaintiff alleged fraud, misrepresentation, or unfair trade practices – regardless of whether or not the accusation was true. Solution: Eliminate the requirement to disclose past litigation. It opens up false accusations. Problem 4: You would have to make a different disclosure for every income claim. Solution: If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." Incomes vary and are private, besides the fact that everyone and anyone can make more than the next IBO. This would just give the prospect a false notion of success. Again, this could be a privacy act violation. Problem 5: You would be required to provide prospects with personal financial documents to back up ("substantiate") any income claim. Solution: IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. Our business for example is moral, ethical and legal and provides not just financial growth, but also personal growth.