| Comment Number: | 522418-11809 |
| Received: | 7/17/2006 3:31:49 PM |
| Organization: | Quixtar |
| Commenter: | Paul Stephenson |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: FTC Proposed Rule Change To Whom it may concern: I have been an IBO with Quixtar for just under four years, and have had nothing but positive experiences form the leaders and mentors I have had the opportunity to be associated with. As a Silver Producer my next next goal as an IBO is to reach the Platinum level and begin Q-12 qualification. The Quixtar business fits perfectly with the lifestyle of my wife & family because of the positive attitudes and personal growth opportunities. The business income and personal freedom aspects are exactly what America stands for from a free enterprise system. When we registered as IBO's we were given more than enough information to make an educated, informed decision concerning the registration process and business ownership. We have continued to provide the same quality information to others that we register in the business. We also constantly relate to our prospects that there are no guarantees and any & all "businesses" require hard work and persistence and that this won't be a "get rich quick- something for nothing" deal! Our prospects typically invest $100-200 to register in the business and have a 6 month - 100% full refund quarantee! Some specific concerns we have about the proposals include: 1.) having prospects wait 7 days before they could register - we feel this uneccessary for businesses where they can get their money back with a simple phone call to the company. If we are meeting with prospects across the state or country, it would require another trip and added expenses. A waiting period would de-legitimize our type of business and imply misgivings, thus indirectly affecting their belief and attitude in dealings with family, friends and potential business owners. Therefore you should eliminate the waiting period. 2.) the requirement to give prospects a list of references - which would be an infringement on the IBO's privacy as well as allow the risk of non-rule abiding persons to possibly coerce the prospect to register with them. Our prospects are encouraged to meet with other business owners in Quixtar to ask questions and obtain their opinions. I would not feel comfortable with other business owners giving my personal information out without my consent. So you should eliminate the requirement to provide 10 references. 3.) requiring IBO's to provide a list of lawsuits, arbitration and legal "claims" (true or not) - which would open up our type of legitimate companies to even more false accusations. The rule is too vague concerning "seller" (possibly including ALL IBO's across the country). It's possible that dishonest companies would even knowingly ignore the rule anyway. Thus you should eliminate the requiremt to disclose past litigation. 4.) make neccessary a different disclosure for every income claim - which would be addressed easily with an " average monthly gross income for 'active' IBO's." All types of business depending on the size, number of years in business, location, experience of owner and work ethic, all have an impact on income. 5.) the requirement to provide prospects with personal financial documents to supoort income claims - which is personal financial data and should be provided "ony" when required for FTC or state agencies in an investigation. Thank you for the opportunity to express my opinions about the proposed rule changes by the FTC. I hope you take into consideration my objections to these ideas and will reconsider their implementation. Sincerely, Paul G. Stephenson Quixtar Independent Business Owner Red Oak, Tx