|Received:||7/16/2006 9:55:01 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:As independent business owners (IBO’s) now for 14 years we have had success and failures. The business has provided our family with additional income but has also given us the opportunity to help others achieve their goals. As adults, our children as IBO’s have applied what we taught them. Our failures are due to not being consistent with showing the opportunity to others. Our team has been supportive in some very difficult challenges in our lives, being there for us is more important than the financial gain. The Quixtar opportunity is a way to be IBO’s, allowing flexible schedules and common goals as a husband and wife team working to promote choices for our team members, allowing financial growth in 2006. We are presenting new prospects information, we state that the Quixtar business opportunity is not a get rich quick plan, that hard work is required, and that there are no guarantees of success. The SA-4400 Independent Business Ownership Plan is given to each prospect to review and keep prior to registration. We also review with new prospects through the Quixtar web site; in an area highlighted especially for new IBO’s called New IBO Info Center. The initial registration fee is approximately $51.50 and optional products, they pay another $60.00. They can get the entire amount back if they decide to leave the business because of Quixtar’s 100% satisfaction guarantee. FTC wants to make sure that consumers have all the information they need to make a good decision about participating in a business opportunity. I agree – that’s exactly why we already provide prospective new business owners with extensive information before they register. Uniform, industry-wide disclosure requirements would also help shut down bogus business opportunities that may try to mimic legitimate direct selling opportunities. The FTC’s challenge is to design a rule that prevents deception without penalizing myself, and other honest entrepreneurs. That said, I believe the original FTC proposal contains several requirements that would impose crippling burdens on my business without doing anything to prevent deception. 1. Prospects would have to wait 7 days before they could register. This would cause additional burden for our business due to additional time, mileage, and other expenses every time a new prospect is presented with our business opportunity. Solution: Eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied. 2. Give every prospect a list of references seven days before the prospect registers. Privacy is a very important issue in the world today and this rule would cause an additional burden to our business. When people register with Quixtar they agree not to use the information listed. Prospects could then use or give the reference list to anyone and the privacy of those listed could be violated. It would also penalize the sponsor, who would be required to give his prospect contact information for 10 other IBOs, any of whom might be happy to register the prospect themselves. Solution: Eliminate the requirement to provide 10 references. 3. Required to list of all lawsuits, arbitrations This requirement would open up Quixtar and other legitimate companies to false accusations while dishonest companies would ignore the rule. Tracking Quixtar or individual IBO’s lawsuits would definitely impair our business growth by spending all of our time contacting Quixtar about allegations instead of helping people reach their goals Solution: Eliminate the requirement to disclose past litigation. 4: Provide prospects with personal financial documents about income claims. Current ethics in our work places encourage pay stub information to be a confidential matter. To offer prospects the financial records necessary to substantiate our Quixtar income would be a required invasion of our privacy.