|Received:||7/17/2006 7:04:28 AM|
|Organization:||M & S Welch|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Item 1: Prospects would have to wait seven days after receiving disclosures before they could register. This would have a major impact on my business. Almost all prospects get involved the same day or within a couple of days of viewing the opportunity. Independent Business Owners generally purchase products at the time of registration, since bonuses are paid on a calendar month this would affect our income. I don’t have to wait to purchase products after joining Sam’s Club or Costco. We should have the freedom of choice; I don’t believe I have to wait seven days before starting another business. The 100% money back guarantee is good for one year, better than Buyers remorse. Item 2: You would be required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other Independent Business Owners in the area – seven days before the prospect registers. It would be against our code of ethics and most likely a violation of the privacy act. No other business is required to provide names addresses of their competitors. Item 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 Independent Business Owners where the plaintiff alleged fraud, misrepresentation, or unfair trade practices – regardless of whether or not the accusation was true. This could not even be enforced. Does anyone know all the legal claims made against Quixtar Independent Owners? Item 4: You would have to make a different disclosure for every income claim. We specifically do not make income claims; we show an illustration of the business works. We make no guarantees. We use averages based on Quixtar documentation. Who would make a business decision based on the ambition of an acquaintance or stranger? Item 5: You would be required to provide prospects with personal financial documents to back up ("substantiate") any income claim. Again, I’m not selling my business, which is willable and transferable. What we are doing is offering someone an opportunity to start his or her own business; their profitability will be based on their activity. One of the best features of the Quixtar marketing plan, is that you can make more money than the person who registered you.