Comment Number: 522418-10654
Received: 7/16/2006 8:04:03 PM
Organization: SoarTech Enterprises
Commenter: Christopher Ayres
State: WI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I have been an Independant Business Owner (IBO) affiliated with Quixtar for approximately three years. Being involved in this opportunity and having the chance to work with the leaders has been an aswesome opportunity for me. I first registered at the age of 20. I'm now 23 and have just begun actively building my business. I've seen some early success and it's been pretty awesome. The last three years have been spent in personal growth learning from my mentors. During this time, I've been able to land a job as a Lead Software Engineer without even having graduated college. I graduate in a year. I would not have been able to do that had I not been involved in this opprtunity. It is an absolutely wonderful opportunity for me as an entrepreneur. In regard to the requirement of a seven day waiting period, it is my opinion that this is harmful to our industry. Though its intentions are good, it's not the way to go about giving people the opportunity to make a quality decision, at least for the Quixtar opportunity. By the time seven days is up, the prospect has often disappeared because they read some website that misrepresents the opportunity as some illegal opportunity that it's not. By this time, it's extremely hard to get ahold of the person to help show them otherwise and show them how many people (including the better business bureau) respect or have good things to say about what we do. It's not a matter of high pressure sales. It's a matter of being able to contact the person at all. A lot of times, they'll disappear by this time if they've got negative from their friends, family, or the internet. In regard to IBOs having to list references, that seems to be a violation of privacy rights. They can give that list to anyone they want and you may not want your name given out to everyone they intend to give it to. Additionally, there are better ways to show legitimacy such as providing a hotline to call to verify the opportunity. I don't mind giving the names and business phone numbers (1-800 numbers) out to prospects, but the home phone numbers and addresses of 10 successful IBOs? It's not a matter of whether we can come up with the names. We can. It's a matter of privacy and not being stalked. In reference to us being required to disclose past litigation, I think that's an unfair rule. Unless you start making wal-mart disclose to everyone who walks in, all their litigation about unfair treatment of their employees, and you start doing the same for all the other companies out there, that rule is completely unfair and bogus. Not only is it a burdeon on IBOs, it's just unfair! The litigation is public record. The public should be able to look it up if they really want to know. However, most won't even read it even if we gave it to them. They'd just assume that we were a pyramid or a ponzi scheme and leave. They wouldn't even give us a chance to review the information with them, which means lost business for us. As far as disclosure claims, I've got no problem with making those if necessary. I certainly want to present this business honestly and fairly and be transparent. However, making disclosures on every claim seems to be counter-productive. It would only burdeon the prospect with too much information and confuse them rather than educate them on the business and what we mean by various claims. If a disclosure is needed, it should be a blanket disclosure that covers everything, not just line-item things. I understand the FTC's need to protect consumers and I applaud that. Honest entrepreneurs like myself are harmed when illegal opportunites are doing their illegal activities. I just want to make sure that us honest people still get a level playing field from which to compete in the free enterprise market. Keep the people safe, but don't make the regulations so tight that us honest people can't have a fair shot.. Sincerely, Christopher Ayres CEO, SoarTech Enterprises