|Received:||7/17/2006 4:05:13 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been Quixtar IBO's for 16 years and it has gone far in giving us many choices. We have enjoyed the fact that this business eliminates alot of the risk that goes with traditional business ownership. We have always been dealt with by our upline in an honest manner and we let people know up front that this business takes work and is not a "get-rich-quick" proposition! We give information to prospects immediately , including the SA-4400 (required by Quixtar when presenting the plan) and let them know that all products have a 100% money back return. In fact that is a very promoted feature about this business! No other industry requires a 7-day waiting period and often they require much more upfront capital. This would also increase the IBO cost of beginning a new business especially if working out of town. That is why a money back guarantee (which Quixtar provides) is more efficient! We have weekly workshops where we provide an atmosphere in which anyone can discuss thier experience as an IBO. This provides a neutral location such as a hotel conference facility and gives the "references" control of how much personal information they wish to give out. I personally would consider it an invasion of my privacy and a safety concern if IBO's in my group were required to give out my personal information to people with whom I've never had the opportunity to meet!!! Likewise, I would not feel comfortable passing out other IBO information as a "reference" without their permission. As far as a litigation list is concerned, it would be totally disruptive to be required to provide this, especially in our litigation-happy society full of filed cases with no merit! Every profession has unscrupulous people. Doctors, lawyers, and contractors (just to name a few) are not required to provide a litigation list to their patients/clients! One dishonest IBO does not mean that all are bad. And there is a vast majority of IBO's operating an honest business. In closing, we do provide a SA-4400 document listing the average income of active IBO's, the bonus structure, and other business plan facts. We also show copies of our personal checks to substantiate the income claims of us personally. We believe that it would be a huge invasion of privacy to provide all financial information to our prospects. This would also hurt the brand new IBO who has not yet generated an income stream from this business when trying to get his/her business off the ground. It is our hope that the FTC will continue to support the legitimate IBO and not harm our business future with unfair and privacy endangering requirements! Thank you for your time!