Comment Number: 522418-09236
Received: 7/14/2006 5:24:06 AM
Organization:
Commenter: Gribble
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Hello, I have been a Quixtar IBO since 1997 or so. Both my immediate and extended family have enjoyed the benifits of this business model for a long time and so I am always keenly interested in any form of legistlation that may affect it. First off I wish to thank you for your concern regarding our industry. As in all professions, there are legitimite businesses operating with integrity and on solid principles juxtaposed with some that do not hold to such a high standard. I applaud your efforts to clear our industry of the people who fail to operate by the Golden Rule. However, it has come to my attention that a proposed "Business Opportunity Rule" is in the initial stages and from all appearances it could use some slight revisions in a few key areas. May I propose to you the following: 1) As there truly is no limit on potential profitability for Quixtar IBO's, I believe personal income disclosure should only be required when asked for by the FTC or a similar agency. I do not wish a prospect to mentally place limits on what they can do with this business model just because I personally have spent several years primarily taking advantage of the wholsale purchasing benifts of Quixtar and not building a larger business. 2) We already disclose income claims for various levels of our business in a clear and concise manner. Any further requirements of this sort would only serve to confuse potential business owners, not enlighten them in any measureable way. 3)Disclosure of past litigation opens up a Pandora's box which would lead to misinformation, disinformation, and false accusations to swirl around through the media and internet and an even more alarming rate. This would not serve to educate the average prospect, but rather would frighten all but the most legally astute away from an industry that they should have no reason to fear. 4) The proposed "10 Reference Requirement" should be eliminated. This is a part time business, and requiring business owners to keep track of everyone else in the community to insure that they are completly "on the level" would be tremendoulsy time consuming. Most people in our industry don't even know 10 people outside of their own line of sponsorship, let alone posess the ability to vouch for them to complete strangers. 5) As a Quixtar IBO, I can see absolutly no reason for a seven day waiting period for potential business owners. We in Quixtar offer a complete money back guarantee. Also, everything that is relevant to the legal aspects of building this business is disclosed up front, and there is nothing shady that will be discovered seven days, seventy days, seven hundred days - or ever - after they register. Thank you for your reading of this and also for allowing this forum for us to voice our concerns. Sincerely, A. Gribble