|Received:||7/17/2006 1:45:28 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My Personal Experience with the “ Quixtar `` A few years ago, my wife and I were looking to make some additional income, after looking at many business opportunities, we were introduced to the Quixtar Marketing Plan. After going through the materials that were loaned to us and checking with the Better Business Bereau, we concluded that we had sufficient information to get started as IBO’s, ( Independent Business Owners) for under $200, we also had a 6 month money back guarantee. Having been affiliated with the Quixtar Company for over 5 years and reaching great levels of success and helping others in accomplishing their goals, I am concerned that the proposed rule in it’s present form would create serious problems for the growth of every IBO ( Independent Business Owner) in our business. My concerns on specific Proposed Rules of the FTC. Problem 1: Prospects would have to wait seven days after receiving disclosures before they could register. Solution : Eliminate the waiting period, at least for opportunities like Quixtar where prospects get their money back if not satisfied. Problem 2: You would be required to give every prospect a list of references e.g. names, addresses and phone numbers of 10 other IBOs in the area.This requirement would infringe the privacy of every IBO whose name, address, and phone number was provided to prospects. This would penalize me as as a sponsor, after providing 10 contact information of other IBOs, one of them may want to register the prospect themselves. Solution : Eliminate the requirement to provide 10 references. Problem 3 : You would have to give every prospect a list of all lawsuits, arbitrations, and other legal claims for the past 10 years involving Quixtar and its IBOs where the plaintiff alleged fraud, misrepresentation or unfair trade practices, regardless of whether or not the accusation was true. This requirement would open up Quixtar and other legitimate companies to false accusations. Solution : Eliminate the requirement to disclose past litigation. Problem 4: You would have to make a different disclosure for every income claim. This is explained in our opportunity presentation. Solution : If disclosures are needed, we have a standard, simple and easily understood disclosure such as “ average monthly gross income for active IBOs``. Problem 5 : You would be required to provide prospects with personal financial documents to back up any income claim. Solution : We as IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agency investigation.