| Comment Number: | 522418-10793 |
| Received: | 7/16/2006 10:34:29 PM |
| Organization: | |
| Commenter: | Aravinth Kaliappan |
| State: | MD |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been an IBO with Quixtar since it's inception on September 1st, 1999. I have achieved the level of Platinum with a 2000+ part-time income which has been able to fulfill some immediate needs for my family and myself. The significance of this income is that I do not need to take money away from my primary income to fulfill these needs and it does not have to be re-created. My next goal as an IBO is to help three IBOships reach my level in thwe business. My business fits very well with my schedule and help me achieve a certain amount of balance with family. Othere benefits are primarily the self development and confidence I have developed in dealing with people and helping them achieve their goals. In has tremendously impacted my self worth as I build people who help build organizations. I received a literature pack with all the necessary numbers and facts that helped me make an informed decision. I have been successful in transitioning the same method in exposing the business to prospective IBOs and give them enough information. I primarily focus on qualifying my prospective IBOs before they get started by providing accurate data on time periods, income and specifically what it takes to succeed in this business. I let them upfront before I start sharing this business plan that they would have to be prepared to change, work hard and learn before they can generate any type of sizeable income. The initial registration is $45 and the optional product pack is $60. Here are some of my personal inferences on the proposed FTC Changes: 1. The requirement of a seven-day waiting period: In the prospective IBOs perspective, this would force them to wait when they have have been given enough information to get their business rolling possibly affecting immediate income that they can generate as this business can be made profitable from day one if one so chooses. It also defeats the fundamental right of the prospective IBO to choose to either build a business on the fast track or not build it or even take more then 7 days to research it if they so choose. A prospective IBO who can do quick research and who wants to be profitable fast cannot be penalized or their enthusiasm extinguished by being forced to wait! I do not see ANY benefit on this requirement! 2. The requirement to provide references: This requirement of providing references of other IBOs is completely unfair as it was the IBO who put in the effort to present the business that needs to be rewarded... not an IBO who made effort on their part to reach out and offer the chance of impacting someone's financial future! Providing the personal contact information of an IBO would not be a violation in my case. I specifically have a systemized method of exposing a new prospect to other team members and expose him/her to them so they can understand who they are, why they do the business and ask questions to clarify concerns. These "Open" meetings which cost the prospect nothing are an investment that the IBO actually makes to ensure that they do get more exposure to the quality of the IBOs. 3. The requirement to provide a "litigation list": To provide information that a prospective IBO can very easily access (in terms of litigations list) would totally mislead oa prospective IBO. This requirement doesn't adequately cover what a "seller" is, meaning that IBOs may have to list all litigation involving Quixtar itself as well as the entire IBO force across the country. This would also not be limited to cases found against the seller but even filed cases with no merit. 4. The requirement for specific earnings disclosures: We are already doing this and would be happy to provide average income/earnings at different levels in the business with an explanation on how averages are computed. 5. The requirement for financial substantiation: We are already doing this and would be happy to provide actual checks from Quixtar to substantiate what's a fact.