|Received:||7/13/2006 9:00:02 PM|
|Organization:||GMT MOM Enterprises, A Quixtar affiliated business|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:The proposed new business rules for direct sellers would be extremely burdensome. As an Independent Business Owner, I do not have access to the financial records of everyone with whom I am affiliated. We do provide disclosures and explanations about the income potential of a Quixtar business to prospects by way of an SA-4400, prepared by Quixtar. We are careful to tell prospects that this is not a get rich quick business. Again, as an Independent Business Owner, I also would not have access to all legal issues dealing with the hundreds of thousands of other IBO's, so I could not provide that information. The income potential in this business is the same for everyone. It is a level playing field. I have been affiliated with Quixtar for several years now. It is my individual efforts in the business that determines my level of income. The rule definitely should not include a 7-day waiting period. Many times an IBO meets with a prospect who is several hours away. It would be very time consuming to require another visit just to complete a registration. The information available on the web and presented to the prospect should be sufficient for an adult to make a business decision. I should not be required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other IBO’s in the area – seven days before the prospect registers. This requirement would infringe on the privacy of every IBO whose name, address, and phone number was provided to prospects. It would also penalize me, if I were required to give my prospect contact information for ten other IBO’s - any of them might be happy to register the prospect themselves. I am sure my representatives on the Independent Business Owners Association International Board will be giving you more precise arguments against these new rules. They represent me and the other IBO’s.