|Received:||7/17/2006 11:45:37 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO with Quixtar since April 2005. After receiving my BS in Computer Engineering and beginning graduate school, I saw Quixtar as a better alternative to working a job for 40 plus years of my life. My immediate goal is to make enough money to be able to focus on this business full time. The reason is not just because of the incredible income potential, but it's the number of lives I can see myself impacting in a positve manner. When I registered I was given enough information to make an informed decision, and I provide everyone I sponsor with the same information. I explain to them that when they get started (for less than $200) that this is not a get rich quick plan; that it is going to take hard work and learning to duplicate others who have achieved success in the business. Most specifically I am concerned with the proposed requirements of a seven day waiting period, references, a litigation list, specific earnings disclosures, and financial substantiation. I believe the seven day waiting period can be replaced with a reasonable cancellation policy. This way I won't be hindered in my ability to help a new person succeed quickly. I believe having to provide references would have a negative impact on my business. I would not feel comfortable with a rule requiring other IBOs giving my name, address, and phone number. The biggest problem I see with references, is taking up too much time. If a person was to have 500 people in their group, and each person in the group had him or her as a reference; that would be a lot of potential phone calls within say a one week period. I believe a litigation list would not be appropriate, because it does not adequately cover what a seller is, meaning that I may have to list all litigation involving Quixtar itself and the entire IBO force across the country. Additionally, I do not agree with this not being limited to cases found against the seller but even filed cases with no merit. I believe that the requirement for specific earnings disclosures for every example used in explaining the income potential of a Quixtar business is unnecessary. I believe the average income for active business owners should be enough, because I do not believe the added detail would make any difference in the prospects decision. Lastly, I would not be happy if the FTC required me to offer prospects the financial records necessary to substantiate my Quixtar income. This would not be appropriate because it would not necessarily give an accurate picture. Especially for individuals just starting their business, and people who have been in for a while but are just now deciding to take it seriously. Overall, all I do feel that it is a great idea to try to protect the general public from fraudulant business opportunites. However, I do see the Quixtar business opportunity as my family's future. Therefore, I ask that you take into consideration that the new rules should contain clear, simple, and standardized income disclosures that apply to all direct sellers; should provide a reasonable cancellation policy; should not require a seven-day waiting period before a prospect could register; shold not require IBO referencs be provided to prospects or disclosure of past litigation; and should not require financial records to be disclosed to prospects. Thank you.