|Received:||7/17/2006 12:21:59 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:We have been thrilled to work with Quixtar since it's launch in 1999. We have reached the platinum level and have enjoyed the corporate trips that quixtar has provided our family. As a stay at home mom, this business provides me the opportunity to be flexible. The income we receive from this corporation allowed me to leave the home care industry. It alleviated the cost of childcare while allowing me the rare blessing of raising my own child! Our ongoing goal is to continue to provide families with a more convenient/cost effective way to shop. Additionally, we benefit personally from the mentorship we receive as well as give. We agree with your rule that we provide simple, standardized income disclosures. We were provided with and give to prospects the SA-4400 and the average gross income per IBO. We feel this is good information to help people make an informed decision. Personally, we would never restrict our opportunity or ability based on what the average person does. Every situation is different. Each person will get a purchasing number for a different reason. By touring someone through our website, they realize, and we point out that each customer and their shopping habits are as unique as the individual, therefore, The profits made per customer will vary. The cost of registration is equivalent to a tank of gas and is FULLY REFUNDABLE if they are not satisfied with their decision. Much like a Sam's Club shopping membership, a person looks at the benefits of shopping online and can immediately register and place their orders. To make someone wait 7 days to purchase their baby formula is not only unfair in a competitive marketplace, but it is a huge inconvenience to the customer who has taken time out of their busy schedule to meet and learn about this site and our products. This would indeed hinder our bottom line by forcing customers who need an item right away to go elsewhere to get it. It would also be a huge time loss to all parties. Requiring more mileage/gas/etc. To leverage time and diminish cost in our business, it is common for us to meet with several prospects at once. To make them wait 7 days before registering other family members/friends would significantly reduce the effectiveness of how we do business. Much like walking through the isles of Walmart, our prospects want the ability to shop when they want as well as share a great value with their friends immediately upon discovering it! We do not agree with the 7 day rule. We provide continuing education for our business developers, which give them ample time to converse with other IBO's re: their experiences. We feel providing a list of references is not only a breach of privacy, but could turn into a huge phone interview process with several hundred people calling monthly. This would not only interrupt the precious time needed to develop business, but also disturb other family members and their privacy. The law was passed to take your name off of telemarketing lists, this would be in essence putting us back on. References should not be required. I also don't feel a list of litigations is relevant. Anyone who is considering an opportunity, can research quite readily online to find any litigation information. For each IBO to disclose their specific earnings would not be an accurate representation of the opportunity. There would need to be a way to calculate the number of active hours of participation. (Vary greatly from each ibo). The goals and intent of the business developer will also play a role in their income. For instance, some IBO's just want to make enough to get their products for free while others are looking to replace a current income stream. I fully agree that as a business owner, you need to keep good books and be prepared to substantiate your income for select government agencies. We fully agree that the consumer needs to be protected. We feel the practices that Quixtar has in place, exceed what the consumer needs to be informed.