|Received:||7/13/2006 11:17:54 AM|
|Organization:||Raut Worldwide affiliated to Quixtar, Inc.|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:We are Swapnil and Uma Raut, (Independent Business Owner) IBO# 1695114 and have participated in the Quixtar business opportunity for over 4 years. We wanted a better lifestyle for ourselves when we looked at this opportunity. Our sponsors showed us the marketing plan, gave us a copy of the SA-4400, told us about the 100% money back guarantee and provided other information we required to make an educated decision. We follow the same tradition and are enjoying this experience. Due to this business, we have learnt and applied success principles, which have enabled us to better our finances, showed us how to set and meet goals as well as improve our quality of life. Currently, we are qualified platinums (25% bonus level plus savings) and have no doubts of achieving Emerald qualification (Help 3 IBOs achieve platinum level) in the next fiscal year. Quixtar has always kept its words be it reimbursement for returned goods, cordial customer support, or payment of accurate bonuses on time. We can count on the Quixtar business opportunity to fulfill all our dreams without compromising on honesty, integrity and our ethics. We appreciate the FTC for always supporting customers and welcome the steps towards preventing fraudulent schemes from entering the marketplace. However, some of the proposed changes would prevent us from moving forward with our legitimate business. We request the FTC to reconsider following parts of the proposed rule. 1. The 7-day wait period: Information is most retained when its fresh and a wait would require us to again explain the business opportunity to the prospect. We only show this opportunity to people who are looking for a business and suggest that a policy of 100% money back guarantee be implemented instead of asking enterprising prospects to wait. Most growth in the business happens based on momentum and a 7 day wait period will give no chance for momentum build up. Also, starting a business is a voluntary process and only adults above the age of 18 (responsible adults) should be allowed to start. 2. Requirement to provide References: The business is growing rapidly with tens and hundreds of new folks taking a look at it. Being platinum, we could be on the reference list of several IBOs in the area. This will affect our privacy and answering phones would take up our productive time. Also, someone with a suspect business model can rig the list of references and misuse this clause to present new prospects with a rosy but inaccurate picture of their business. 3. Provide with a Litigation List: Even today we don’t have the list of all litigations against Quixtar and it is a blessing for our business. It allows us to focus on the positives and keeps our minds creative. Also, any litigation when resolved is of value to the new prospects as we are not aware of the truth when the result of a litigation is pending. Asking prospects to check with FTC for legitimacy of a business model can be added as a rule. 4. Specific Earnings Disclosure: We share the monthly average income made by ‘active’ IBOs and also provide the SA-4400 which clearly states the amounts of money that can be earned utilizing this opportunity. We think, a clause to show the average monthly income should be made a rule. 5. Requirement of Financial Substantiation: There are couple of reasons to not make this a rule in our opinion. First, how much money we make is a private matter and others should not know it. Secondly, IBOs who have joined earlier, will have stronger finances than the new IBOs and it will make it more difficult for new businesses to start and get going. Instead, having a legal document such as SA-4400 makes the business a level playing field where people can determine how much money they make based on their work ethic.