|Received:||7/13/2006 10:06:34 AM|
|Organization:||Lightning Enterprises 3830819|
|Commenter:||Cynthia L Meshanko|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO for a little more than 2 years with the BWW and Quixtar.com business system. I feel very strongly that proposed rule 16 CFR Part 437 will be a great detriment to my business. All of the people I have contacted as prospects during these 2 years were wary that this business model was another scam. Hence, I very much appreciate that you are trying to combat the individuals and organizations that are, in fact, out to cheat people. However, I feel that the requirements to provide references and also to provide financial substantiation are impinging on the right to privacy of my associates and of myself. The largest portion of my prospects are cold-contacts; I know absolutely nothing about these people and vice versa. In this situation I am very hesitant to give them names, phone numbers and/or addresses to individuals with whom I am associated. I want to give every person the benefit of the doubt, but I also have to be practical and realize that there are unethical, immoral, and violent people walking around the streets freely! Also, I do not feel that my personal financial records should be open to a prospect. I work with a large team of associates and I introduce and refer questions from my prospects to those folks who have already reached the levels of success that we are permitted to advertise or discuss according to the FTC business model for Quixtar. The team meets weekly in the home of the most successful family in our association and all prospects are free to tour the home and see the lifestyle this couple has achieved through this business opportunity. There is no point in inviting prospects to tour my home and view my lifestyle because I have not yet achieved that greater level of success. This would cause every prospect to question any statement I might make about the validity of the business system. Also, the waiting period of 7 days before registration is a huge detriment to my business system, because each month profits start at zero on day one. So if the 7 days falls over the end of a month, I've lost out on any possible benefits from that new prospect's participation in my business for that month. I also find the requirement for disclosing past litigation to be burdensome and inappropriate. After all, anyone can google Mother Theresa and find accusations and false claims about her works and character! I refer my prospects to the websites of the FTC, the Better Business Bureau, and the IRS, in order to research Quixtar and get all the information they need in order to make an educated decision. This business opportunity is not for everyone, and it is not a get-quick-rich scheme, which disappoints many people! For this reason I provide my prospects with literature, CD's or tapes, books, and other references and websites that will give them the pros and cons of this business. This business system works and I do not need to convince anyone to join up with me. I invite people to participate in the team that is growing in my area of Pennsylvania only if they are looking to work to make a supplementary income that could, in time, develop to the point that they could decide to retire from their full-time job. I am afraid that the requirements that are proposed will seriously limit my ability to point out the benefits of my business opportunity. I respectfully request that you consider eliminating these requirements from the proposal. Thank you.