|Received:||7/14/2006 5:12:26 PM|
|Organization:||Quixtar/ Boyd International|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:We encourage any effort to reduce the number of 'get rich quick deals' that come along, but do not want to see rules which would restrict the honest efforts of the many legitimate businesses in Direct Marketing. Just getting started as an Independent Business Owner (IBO)in direct marketing and looking to create a stable retirement for my wife and myself, we have great concern for the harm your proposed 'Trade Regulation Rule on Business Opportunities' would cause us in our retirement years. I believe the FTC and other regulatory agencies are vital to our business economy and are doing a good job of protecting people from harm in our industry. Our company's policy and that of our organization is to always clearly inform people that the amount of success they have is based on their own efforts, and no one can guarantee them anything other than an opportunity to succeed. We and our organization provide all new prospects with the average earnings of Independent Business Owners(IBOs) in the Quixtar Business as required by the FTC. We also inform them that over 1 billion dollars in profit has been earned by IBOs in the first six years of the Quixtar Business model. The fact that our plan and the associated products are delivered with a complete satisfaction guarantee is of great importance to us and insures that no one can be financially hurt. Even the cost of our business kit, registration, and sample product pack (less than $150 total) is refundable if someone changes their mind - even if they have opened the product(s). This is a much better arrangement than having someone wait 7 days before they can register and get started in their own business. We believe the first few days after seeing the business plan is critical in getting them into action and moving them ahead with the help they need to see their own efforts turn into success. Providing a list of 10 IBOs in their area is an invasion of privacy. Revealing names, phone numbers of associates, is not condoned by most establishments with whom we do other retail business. By the same token giving out the names of competitors, that is other non-affiliated IBOs, is helping the competition and that is not considered good business practice by any company we know of. We provide 'second look' meetings for new IBOs where they can review the Quixtar model in more detail and meet other IBOs. They can visit in person to get other inputs and experiences. Our opinion is that the legal conflicts of other IBOs have nothing to do with how we do our business. Personal integrity and responsibility is at the core of our, and any other business success. Thank you for considering these points of concern. We could add more, but we are trying to hit only key areas of concern in an effort to keep our response short.