|Received:||7/13/2006 6:37:06 AM|
|Organization:||Skinner International Enterprises|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am an Independent Business Owner affiliated with Quixtar.com. I applaud the government's desire to take action that would curtail fraudulent "business opportunities" that take advantage of those who wish to better their lives. However, I have numerous concerns regarding this proposed rule. #1- Lawsuit disclosure. Given that there are literally thousands of IBOs across the country and world, affiliated even just with Quixtar - all private citizens with their own businesses, acting INDEPENDENTLY - to simply collect this data is prohibitive. Also, in fraudulent situations, to use an example, a person willing to commit murder using a gun won't flinch at buying it illegally. A "business" willing to defraud someone will have no qualms lying about previous legal action. This is burdensome to the honest and irrelevant to the dishonest. #2- Income disclosure for all levels. To require this for every last example would be like having McDonalds having to disclose every possible combination of sales of burgers, etc, for not just one year, but five. The Quixtar business plan has always, in my experience, been shown as a two to five year plan, following the 6-4-2 model designed by Harvard Business School, and APPROVED BY THE FTC after years of research. I'm presuming there was a reason that this simple format was acceptable. There are so many possible permutations in possible structure that it would take a plan the size of a phone book to show them all. #3&4 - Personal financials & local contacts. We are INDEPENDENT business owners. What I make, based on MY OWN work, does not determine whether or not someone else will succeed. I have often seen people register, only to have the one who registered them quit. It happened to the person who registered me. That is exactly the reason why this is a great business opportunity. My success doesn't depend on other people's financials. The only financials I am concerned with are Quixtar's and that of my mentorship team, Britt World Wide. I have always gotten what I've been promised from them, and never had a check from them bounce. THAT is what I'm willing to confide. They are the one's providing the revenue, not the person who registered me. Giving a list of local IBOs information is an infringement on their lives and businesses, and as business grows, there often AREN'T any LOCAL owners in new areas. There are several opportunities to meet other IBOs already built into the mentorship program, and providing names and numbers won't add any benefit. Finally, while I am totally committed to having a and working with credible businesses, caveat emptor. The legitimate businesses have their credibility out there already, and the fraudulent ones don't. I can go directly to the Better Business Bureau from the Quixtar site and look up where it stands from that and other third parties. In fact, every time I have seen the 6-4-2 plan shown, prospects are TOLD to look it up with credible third party sources, and to not just take our word for it. We have recommendations for where to find that, certainly, but they are still third party with no influencial relationship to us. It is the nature of the entrepreneurial system to try to succeed for yourself. In that lies responsibility on the prospect to do their own due dilligence. I am sorry for people who are taken advantage of, but part of that lies in their own lack of investigation of the business they are looking at. People are people. Bad decisions still get made. Please don't make it more difficult for the honest business owners to succeed by trying to legislate against ignorance.