|Received:||7/16/2006 10:46:56 PM|
|Organization:||Legacy Business Group|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar IBO (independent business owner) for a few years now. While I'm still working towards attaining financial freedom, I have achieved more than I had imagined when I first started. And this business is much more than making money. The positive atmosphere has helped me become a better person. My self-esteem has grown. My faith in people has been restored. Even when I'm not building this business, I'm using principles that I've learned from this business. When I share the business plan with people, I share my Quixtar experience with them. And I always leave them information to go over for the next 2 days, just like my sponsor did for me. Heck, it's only a small % of people who register on the spot anywway. I always tell people I can't promise them anything; this is not a "get rich quick' plan, that it takes time and effort. Plus, the information I leave them will tell them the same thing. When they do register, the cost of $326 or 330 (which includes many products) gets them started the right way by introducing them to many of our top consumables. And if they change their mind, it's 100% refundable. Since I've never had anybody want their money back, I don't know how much they get back, if they used up all their products. From my experience with the corporation, they'd probably get all of it back. As for the proposed rules: 1) 7 day waiting period. As I stated in above paragraph, new IBO's can get their money back long after they register (incl. $ for the products). So nobody benefits from the 7 day waiting period because A) During the 7 days, someone else may contact them and register them 7 days later or B) They may talk to someone whos has no experience w/ this type of business (or any business whatsoever) but will tell them why this won't work. Negative thinking people will kill their hopes and dreams. C) They register, but they have to wait 7 days to register family and friends. Their excitement will wane due to inactivity in regards to actually registering people. Some people need to see immedate results. This will hurt their income potential and in turn, will affect mine. SOLUTION-- Waiting period is only for those businesses that don't offer a money back guarantee. 2) Provide 10 references. A) This infringes on my privacy and the privacy of the 10 IBO's. I' m uncomfortable with another IBO giving out my address and phone # to a complete stranger. B) There's a risk that the prospect would register with one of the references. Considering, I did the contacting and showed the plan, that wouldn't be fair. SOLUTION - We already have a built-in one. They can meet and listen to other IBO's at meetings, seminars, etc. to get the info they need. So, eliminate requirement for 10 references. 3) Provide a litigation list for the last 10 years. Seller is not properly defined. I may not only provide the Qixtar list, but for every IBO across the country who was litigated. And not just cases ruled against the seller, but those that had no merit.. This is going to open us and other legit companies to false accusations. Of course, illegitimate companies will dodge this one. SOLUTION-- Eliminate requirement to disclose past litigation. 4) Specific earning disclosure. Obviously, I show them income potential and how it progeressiely gets bigger. They understand that, but to stop the flow of the plan with MORE numbers would be disruptive and would make the plan last longer, which increases the chance of losing their attention. The SOLUTION is already here. Our SA-4400 discloses the average monthly gross income for active IBOs. I show this either during or at end of presentation. And I leave it with them. 5) Personal financial substantiation. I don't show people my financial records. A) They may be criminally inclined. B) There may be $ in that account from other sources. SOLUTION-.Only for FTC or similar state agency investigations.