|Received:||7/17/2006 11:02:17 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar IBO for the last 3 years and have reached the level of 1000 PV. I believe it is a great opportunity to own a business without the risk and the capital of starting a business. I provide my prospects with information such as the average gross monthly income for active IBOs and also inform them of the work it will take to make the incomes highlighted in the SA-4400 business plan. New IBOs on typically get started as a part of my business team for less than $170 (which includes a starter product pack). I let them know that this is not a get rich quick opportunity before they even see the business plan or have the opportunity to register with the business. I don't believe a 7 day waiting period is needed for a business, like the Quixtar business, that allows for a full refund of the startup cost. A 7 day waiting period is not seen in other industries, therefore it would be unfair to impose such a limitation on the direct selling industry. Additionally, I believe that if an IBO were forced to provide a list of references to a new prospect, it would hinder the growth of their business because there would be a risk of the prospect wanting to join with an IBO who is more established. Such a rule would make the opportunity less equal to the new IBO. At our meetings, prospects have the opportunity to speak with other business owners in the area and ask them questions. In this way, they are able to acquire the information they need to make an intelligent business decision. It would be entirely unfair to force the disclosure of a litigation list to prospects in today's litigation-happy culture. The same is not required in other industries. Finally, there is no call for the invasion of privacy by forced disclosure of financial information from individual IBOs. Forcing a new IBO to disclose such information would be akin to a new restaurant owner having to point out the fact that he has never made any money in the restaurant business to all his prospective employees (how would that affect his/her chance of success). It is simply not done in other industries and for good reason. Overall, Quixtar provides ample restrictions and measures to keep IBOs in check and provide a stable, sustainable, and honest business opportunity. Any additional restrictions would not benefit or protect a prospect, but only serve to hinder an IBO.