| Comment Number: | 522418-11287 |
| Received: | 7/17/2006 9:52:12 AM |
| Organization: | |
| Commenter: | Richard Becker |
| State: | MA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom it may concern, I have been an Indepedent business owner contracting with the Quixtar Corporation for 11 years. At the time I registered I was given a comprehensive document that we call the SA4400 provided by Amway at the time which disclosed the average income of business owners and other relavent information. It was clear from the documents that I was given that this business could work but that it would not be easy. At the time I was the COO of a publicly traded software company. As we sponsor other folks I make sure that new people get at least the same information that I was given. We have achieved the Platinum level in this business and have helped start over 300 people in this business. This business takes work and we try very hard to make sure that new people understand the prospects of success before they are registered. Our experience is that if people do not have a realistic perspective they end up wasting their time as well as ours. I understand the intent of these new rules and I think that some type of rules are required. I do hove some comments however relative to some of the disclosure items. EARNINGS DISCLOSURE- In the presentation of the business plan I do not disclose how much I make. I give examples of how much you could make based on the the document called the SA-4400 or TL440 which are supplied by the Quixtar and Internet Services businesss. The percentage of people who have attained various levels and incomes is clearly stated. This a simple repeatable process that can be duplicated throughout the organization. I think that this will satisfy the requirement with out having to provide personal financial statements. A requirement such as that would severely impact our business as it would discourage new business owners from presenting this business to others. PROVIDING REFERENCES I do believe that prospective business owners should get some additional information in addition to the initial business presentation. Providing a new prospect with a list of existing business owners would severely infringe on the privacy of those business owners and would again severely impact our business as new owners may not want to have their names given out. I would suggest eliminating this requirement LAWSUIT DISCLOSURE My experience as a business owner in this business as well as prior has shown that this type of disclosure is difficult to adminster and therefore would not be worthwhile. We routinely direct people to the Better Business Bureau where complaints and other references of this type can be found. We also direct them to comments of other reputable companies who contract with Quixtar. These references can be understaood by the average type of person that we present to and it is a precess that can be duplicated throughout the business. Adding this requirement would severly impact our ability to grow this business in that it could be too cumbersome for new business owners to undertake. 7 DAY WAITING PEPRIOD We encourage new preospect to get enough information to make a valid decision prior to signing up. The fact that the new prospect can get his or her money back at any time makes the seven day waiting period superfluous. We insure that the prospects understand this process. Again our goal is to sponsor people who have a realistic understanding of what success will require on their part. If an individual registers and totally underestimates their commitment requirements then our time as well and the new business owner's is wasted. I believe that our business and the business of new owners would be negatively impacted by this 7 day waitng period. With the money back guarantee from Quixtar the waiting period is not necessary. I understand what the goal of these rules are and we appreciate that. I think that exceptions or elimination of some of these requirements are extremely necessary to insure that these businesses can continue to prosper.