|Received:||7/17/2006 12:17:51 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To whom it may concern, My name is Mary Trefney and my husband Donald and I are Independent Business Owners (IBO’s) with Quixtar. Our adult children are also registered IBO’s in the business. We have been in the business for 20 months and our children for longer than that. As we have begun to grow our business we have come across skeptical people who have dealt with unethical business practices in other business ventures, other than Quixtar, that may not have been totally honest with them. Unfortunately this often paints a negative picture for all direct selling companies which impacts the reputable companies like Quixtar. We applaud the FTC’s efforts to make sure that all prospects of companies are completely informed in order to make an educated decision on participating in a business opportunity. However, some of the proposed restrictions may actually hinder the honest, reputable companies instead of the unethical violators that you are trying to address. The proposed waiting period of seven days should be unnecessary for companies that have a money back guarantee if they are not completely satisfied. Quixtar offers this and honors the refund for any circumstances. A friend of mine registered as an IBO and for personal reasons, (a divorce), decided this wasn’t the right time for her. She thought very highly of the company, but decided she couldn’t commit to a business at that time. She contacted Quixtar and was refunded her money. If a company does NOT offer a refund policy, then I can understand that restriction, but it should not affect companies that have a refund policy in place. The waiting period takes the most exciting time of a new IBO’s business launch and brings it to a screeching halt. It is an unfair restriction that would negatively affect all Quixtar new IBO’s who are excited and eager to get off to a good start to build their business. Please don’t cripple the companies that have refund policies in place, who demonstrate their willingness to provide that same protection the seven day waiting period does, without penalizing the most exciting time…..their new business launching. The proposed required list of references names, addresses and phone #’s of 10 IBO’s in your area, seven days before registering is very disturbing to me. One reason for the same argument stated above. It stops the most exciting time of a new IBO’s business launch if you meet with a prospect and they are ready to get started you would then have to give them the references and wait seven days to register them. That is crippling to this organization and its successes. Even more disturbing is the infringement of privacy of IBO’s whose personal information is given to prospects. It also hands over your prospect directly to other IBO’s who are interested in registering new IBO’s as well. What if, in that proposed situation, your new prospect calls the references and finds a common interest or acquaintance with them and decides they may want to register with the reference now instead of the original person who contacted them and showed them the business opportunity? This opens up a huge area for unfair business practices that would cause more negative implications than positive. Quixtar IBO’s currently have the opportunity to MEET other IBO’s in the area when we attend hotel opens, which are meetings that are held in various hotel locations throughout the month. So that opportunity is provided through Quixtar without violation of privacy of current IBO’s. Please eliminate this proposed requirement and if necessary have a list of people on the Quixtar site that have offered to be a reference if it is required. I also disagree with the proposed disclosure of any litigation due to false accusations & claims. I recommend a simple disclosure statement of average incomes of certain levels. Thank you for your efforts to protect reputable direct selling companies and differentiate between the unethical companies. Respectfully, Mary Trefney .