| Comment Number: | 522418-09396 |
| Received: | 7/14/2006 1:43:30 PM |
| Organization: | |
| Commenter: | Marti Baer |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been a Quixtar IBO for more than 10 years. The IBO organization I'm part of provides me with training and friendships, both of great value in my day-to-day life. Using the system, as it currently exists, I have NEVER had any difficulty with prospects, IBO's or customers. I provide prospective IBOs with any information requested or refer to an appropriate source. And we carefully point out that this is not a Get Rich Quick scheme. We talk in terms of years and the amount of work it actually takes. When I registered, not only did I receive enough information to make a decision, it was RECOMMENDED that I do my own research and ask questions...all of which were answered. The rules were made very clear to me in the beginning. I knew what money could be refunded. I knew there were no minimums or maximums. I knew that I could always ask questions and get proper answers. When I sponsor IBO's I do the same for them and make sure that I get them to the person who can get all their questions answered. The 7-DAY WAITING PERIOD seems to serve no purpose...if someone wants to start right away they should have that option...if someone doesn't want to work with us that's okay too...7days won't make a difference. We already provide references...through THISBIZNOW.COM and providing access to our upline and the company. The Internet provides plenty of access to the information that might appear on a LITIGATION LIST. When I registered as an IBO, I figured that ALTICOR and QUIXTAR were so large that they were bound to have lawsuits against them. As most lawsuits filed are of no merit, this would force responsible IBOs into the unreasonable position of having to explain any and all lawsuits. Most of us have no legal background...the potential for confusion and mis-representation are actually increased by this poorly thought through requirement. When people shop at Wal-Mart or are looking into possibly opening a Subway, they don't expect to receive a list of lawsuits. Quixtar and most of its IBOs are respectable, responsible people who should not be penalized for the actions of an irresponsible few. Regarding SPECIFIC EARNINGS DISCLOSURE, we currently provide prospective IBO's we enough detail to make their decision to work with us. The FTC approved SA4400 and our willingness to discuss the details make this an unnecessary burden. In order to respect people's valued time, we try to keep our presentations to 1 hour. We ALWAYS let them know that the numbers in the presentation are a) FTC-approved and b) JUST an example. I feel strongly that complicating this can only cause more confusion and chance of misrepresentation when the marketing plan is presented. FINANCIAL SUBSTANTIATION makes virtually no sense. IBO incomes are based on the degree of action taken by individual IBOs to properly sponsor new IBOs and acquire customers. New IBOs who have only been in the business a month or two have nothing to disclose. IBOs who have been around a while but only just recently started expanding their business have nothing to disclose. IBOs who developed their business, then let it founder, then re-developed it have confusing and non-motivational information to disclose. Again this sort of information provided to a prospective IBO will cause greater confusion and potential misrepresentation. How much money I choose to create with my personal business is My Personal Business. However, we know for a fact that those who choose to put in the effort produce excellent results. We have considered the FTC a valued partner in our business. We point out that the numbers we present are approved by the FTC. We are careful to present the information as potential incomes...not hard numbers. This level of interference and potential confusion added to our businesses as the result of a few people, who probably did something illegal or unethical themselves, is unnecessary and likely to cause many more problems than it solves.