|Received:||7/17/2006 2:18:35 AM|
|Organization:||Quixtar Independent Business Owner|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been Quixtar IBO's since its web launch in 1999. We have enjoyed our business and believe its a great opportunity to own a business without all the overhead of a traditional business. When we were registered in business, our sponsors let us know up front that this was not a "get rich quick" deal. They also let us know that if we weren't willing to work like a business owner we would not succeed. In short, they have always been honest and truthful with us. We were provided, and still provide today to others, the SA-4400 which Quixtar requires us to give out when we show the business plan to a prospect. The SA-4400 is a form that includes typical IBO earnings and shows a general model of a networking business. We let the prospect know up front that registration with Quixtar is around $150 and that it includes a product pack that the new IBO chooses as well as access to quixtar.com. We also let prospects know that there is a buy-back policy if they are not satisfied. A mandated 7 day waiting period is not necessary. If you have a buy-back policy (which Quixtar does), why would you need a 7 day waiting period? This limits (or raises expenses of) the sponsoring IBO a great deal. For example, if an IBO lives in Atlanta and is expanding his business base in Chicago the 7 day waiting period requires the IBO to travel twice as much. On a weekly basis, we have a workshop that provides an atmosphere for open discussion. In this environment a prospect has the ability to talk to many IBO's openly and freely. This is the easiest way for a prospect to have access to "references," without infringing on the IBO's privacy. This provides a controlled atmosphere where people meet in a neutral location, like a hotel meeting room and does not encourage trying to recruit the prospect there for personal gain. The idea of providing a litigation list is absurd, unless you are requiring all business to do so. Every profession has unsavory representatives. Why should I as an individual business owner have to bear the sins of someone I don't even know. Cases filed with no merit would unduly influence prospects. Regarding earning disclosures, as mentioned above we provide to prospects the SA-4400 which lists the sales plan, business earnings for sample businesses, and the average monthly gross income for active IBO's. We do not provide specifics about gross monthly or yearly income. It would be a gross invasion of our privacy to have to disclose all financial information to prospects. We hope the FTC will recognize and support the legitimate Independent Business Owner and not hurt us with unfair requirements.