Comment Number: 522418-12473
Received: 7/17/2006 10:06:35 PM
Organization: World Information Network
Commenter: Tony Crabtree
State: MO
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

My wife and I have been IBO's for five years now. When this idea was shared with us they were very patient with us because we took eight weeks to make a decision. We saw the presention from six different IBO's in a variety of settings, meetings and personally. We were given plenty of information and time to make an educated decision, but were very shy and had no business owner mentality. So it took us a while to believe that we could build a business. But because of excellent mentors and our personal developement program we have achieved Founders Platinum status and have maintained it for two years and are on track for it again this year. We are shooting for Sapphire March of 2007. When we share our idea with others we tell them right off the bat that it is not a get rich quick plan and even if they want to register the night we show them that they should listen and read the information that we have for them and come to a meeting to see the idea from another IBO so that they can make an educated decision for their family, based on information, not emotion. When they do make that decision to register, they typically spend an average of $300.00 to get started. This is a very small start up cost for any business. When we started our table top business we started it with $25000.00 which our accountant called; blue sky. And if we would have not made that business successful we would not have gotten any of that money back. But, the company we partner with will issue a refund of the cost of the IBO's access to the order consolidation site. And all of our business meetings have a 100% money back guarantee. The part of the start up cost that covers their product pack can also be returned for a full refund . To address the specific issues that we feel are unreasonable, we would like to first start with the requirement to provide references. We feel that giving prospects a list of other IBO's in the area would be a substancial risk of losing the prospect to other IBO's. In addition to giving out other peoples information, the thought of them giving out our personal information to just anyone doesn't thrill us either.We feel that would violate our privacy and the privacy of the other IBO's. Second, we feel that the requirement of providing a list of litigations involving the seller is not clearly defined. As an IBO we enter into a contract with the order consolidation site, Quixtar. If the seller is Quixtar how would I even obtain that information, and how would you separate the valid cases verses the cases that have no merit. If the seller is us, we have never been involved in any litigation of any kind, but I still think it's not fair. Will it be applied to car salesmen? Talk about fraudulent, unfair , deceptive practices! Third, If we were required to make a separate disclosure for every example we used in explaining the income potenital of our business, it would be so confusing and cumbersome to carry around thousands of examples. We have and use the SA-4400 that picks one example and applies the compensation program to that example and we all use it. Everyone is on the same page when sharing our idea and it makes it less confusing to the new prospect. We do tell them it is just an example and that they have the right to build their business the way they feel is best. Forth, finacial statement to prospects. The only numbers we share with prospects is the SA-4400. We never discuss our personal income. This would be inappropriate. We do discuss the impact that our mentors and the personal developement program has made in our life. We have a better marriage, are better parents, and much better business owners. To ask us to provide a prospect with finacial records to substantiate our Quixtar income would be crippling to a new person. If our income is really high, they might feel that they couldn't ever achieve something like that and not try. If it's low, theres no belief. Thanks