| Comment Number: | 522418-11870 |
| Received: | 7/17/2006 4:13:55 PM |
| Organization: | Kinyon |
| Commenter: | Sarah Arzaga |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My Name is Sarah Arzaga I became an IBO in March 1999. It was one of the best decisions I’ve ever made. When I was introduced to the business plan, I saw a way to create residual income and security for myself and family. I didn’t see many intangible benefits like, improved communication skills and understanding of personalities and the power of setting goals and the joy of achieving them. We were able to reach the 23% on the bonus chart and help others in our group do the same. Along the way, we learned to promote excellent products, teach others how to create and maintain household budgets and become more savvy about consumer debt and how to manage it. When I registered I received sufficient information to make an informed decision. I felt good about the integrity of the bonus plan. I knew that I would be supported by my team to build a successful business and was certain they would share all relevant techniques and approaches. The products are innovative and of the highest quality available on the market. When we sponsor others onto our team we ALWAYS provide similar information. We support the individual with whatever is needed. If someone wants to, but doesn’t have the money to attend an educational seminar, we will have a garage sale or other fund raisers so that they can attend. All of our prospects are informed that this is not a get rich plan and that it is not easy to move-up the bonus scale without hard work, and investments in time and resources. We stress that success is up to them and like life, there are no guarantees. The initial registration fee is about $325 and includes a wide array of household products and goods. This packet is designed to assure that new business owners will get a bonus check, based on their volume the first month. If they chose to leave the business, they can send the products back and receive a full refund.SEVEN-DAY WAITING PERIOD This is an unnecessary delay. We provide a written plan to all prospects to read and review, they are informed and ready-to begin building their business. The delay could mean far fewer people getting involved if the new IBO in turn had to wait seven more days or more before registering their friends and families We often travel to cities other than our own to build our business, the waiting period would mean we would need to travel a lot more and incur a lot more expenses on gas, air flight, meals and baby sitters. This would make our business a lot less profitable. PROVIDE REFERENCES We do provide all new IBOs with a chart of the support team members and contact information for those on the team that will directly be working with the new IBO. Because of privacy concerns identity theft and personal safety, it is not wise to have this type of information given to any prospect. It violates privacy and is not safe for the single women building the business. The DMV doesn’t release records this way, nor hospitals Note HIPPA rules, which don’t even release medical information to spouses not given permission or universities.THE LITIGATION LIST Is arbitrary and capricious, it has no value or merit. WalMart is not required to disclose this information, nor are our public figures such as Senators, Mayors, and the President of the United States. If anyone is really that interested, they can obtain this information using a search engine anyway. Why give it to people who may not understand legal language, or the context in which it is written? REQUIREMENT FOR SPECIFIC EARNINGS We always provide the SA 4400. The financial disclosure is not hidden from view or scrutiny. Never, would you demand to see your colleagues or a boss’ paycheck stub before deciding whether to accept a job offer. This is a violation of privacy and should not be implemented. REQUIREMENT FOR SUBSTANTIATION College degree on my resume for a prospective employer, I didn’t provide a transcript to prove my grades and degree. Why should I? not all Drs have great grades, but the received their MDs