|Received:||7/17/2006 3:53:56 PM|
|Organization:||Teambuilders in association with Quixtar|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:As an Independent Business Owner(IBO)with Teambuilders for Quixtar, I applaud the FTC's desire to provide potential business owners protection against fraud from unethical business opportunity sellers. Quixtar, and its predecessor, Amway, are legitimate multi-level marketing businesses, which have provided many with the ability to provide financial security for them and their families. Everyone who starts out in this business is a small business owner, many with minimum income who become IBOs, because they can afford to with a registration package from $45 to $125 plus tax and shipping. They are guananteed 100% refund on any Business Support Materials (BSMs)and products they buy for 180 days. There is absolutely no pressure for them to buy the BSMs, products or any training materials or attend any business related meetings/conferences, although they are told that these things have helped many to reach their goals quicker, but are not mandatory. I have been an IBO since Dec 2001, but was unable to be active for several years due to my husband's illness. I am now actively trying to build my business and want to concentrate on those who currently are low income earners to help them become financially free. Some of the proposed requirements in the new business rule would cripple my efforts. The definition of Seller is not clear. If it means Quixtar, or IBOs, or Quixtar and all of IBOs, there is no way that I would be able to find all of the litigation required in the list, nor be able to keep it current. I would have to hire a lawyer try to do so, as would other existing and new IBOs, a burdensome expense. I'm not sure that even Quixtar would know every litigation against individual IBOs. The monetary cost of providing a current list to every propect would be prohibitive to Quixtar and me and the impact of being given such a list would make any prospect decide he/she would not want to be associated with me or Quixtar. This requirement should be deleted. Providing 10 references of other IBOs would give the other IBOs the opportunity to sponsor my prospect after I had made the initial contacting effort. It would also invade my and the other IBOs privacy, especially dangerous in today's environment. Having to substantiate my income, means that I basically would have to provide portions of my income tax submission to strangers, which is none of their business. Each IBO builds his/her business differently and to try to get, much less maintain, information to validate range of income is impossible, and again an invasion of privacy. When the Teambuilders Business Plan is shown, and at registration, figures are shown which give income figures based on volume with disclaimers indicating these are potential income figures, not guarantees. Also, the average monthly gross income is diclosed when one registers to become a Quixtar IBO. We always stress that you have to work hard to make this business work. The requirement for a 7 day waiting period to register does not fit with the proven time frames in Teambuilders/Quixtar for contacting, showing the business plan and following up. Some want to register immediately; others take more time, which we give them. A mandatory seven days gives the prospect time to talk to family and friends, who have not seen the plan, do not understand the concept, and may discourage the prospect's enthusiam. They might listen to those in the 95% who have 5% of the money and not the 5% who have 95% of the money or those who wish to be in the 5%. The litigation list, the 10 references, the financial disclosure, the substantiation, and the 7 day waiting period would destroy my business potential and that of so many low income families. They need to be eliminated. The beauty of this business is its relatively low cost of business ownership, its flexibility in recruiting, its money back guarantee, proven mentorship, and great opportunity for fianancial freedom.