|Received:||7/17/2006 10:23:15 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am Jonathan Reynolds, former US Marine Sergeant. Quixtar IBO # 3378220. I have been a Quixtar IBO since 2004. After a slow start I have a healthy growing organization with a gross of over 35K in sales a year. After 4 years in the Military, I was faced with low employment opportunities. My sponsor (my Father), a USAF Retired Colonel, more than adequately prepared me for the Quixtar experience and business model. He clearly explained the business from top to bottom as well as the approximate monthly and yearly cost of running the business. I understood it would take work without guarantee of a specific financial reward. With start up cost ranging from $55 to approximately $250 dollars, I started my business while I was on active duty and then allowed my registration to lapse since I was deployed. After I got out of the Marines, I elected to invest in the full getting started right package including sample products. It was never presented as a get rich quick business. I benefit from the strong mentorship of my father as well as the entire Britt World Wide organization and continue to prosper in this unique business. Like my dad, because of the strong emphasis on Family values, loyalty to country and support of our Government, and Free Enterprise, I believe Quixtar alone should get a government stamp of approval for all Active Duty, AFRES, ANG, and retirees with strong government support through the SBA for business start up support. Particularly in the transition from active duty to retirement. Additional DoD legal language encouraging business development and growth on active duty should be encouraged. I have read your proposed package and offer the following comments. 1. Problem 1, waiting period. Waiting periods can prevent emotional business decisions particularly for lost start up investment. However, I do not believe a waiting period is necessary for the business that offer a 100% money back guarantee as Quixtar does. 2. Problem 2. I do not believe I should be required to present 10 references to a new prospect. When I got started I hardly knew 10 people in the business. This is a competitive business and it would provide a competitor organization access to my prospect without compensating me if my prospect were to join their organization with my use of their name for a reference. 3.Problem 3. I believe providing a prospect a list of all lawsuits, arbitrations, and other legal claims for the past 10 years would encourage a competitor to file baseless lawsuits. I would be unprotected and even vulnerable to false allegations and would not be able to defend myself. I would not have access to due process of law. It would seem to encourage frivolous lawsuits meanwhile; dishonest companies would ignore the rule. I do not believe a past legal action bears weight on the future except to ensure best future business practices. Once again, this would appear to bear more on companies that do not offer a 100% refund for start up expenses. 4. Problem 4. Disclosures of income claims. If disclosures are required, require a simple, standard, easily understood disclosure such as an average monthly gross income for ACTIVE IBOs only. The current disclosure is very misleading since it includes both active and inactive IBOs. It skews the data to a lower average income for current active IBOs 5. Problem 5. The requirement to provide prospects with personal financial documents to back up income claims could be misunderstood and even discouraging since the prospect might judge his opportunity by my performance and that depends on their efforts not mine. However, we should not be exempt from standard disclosures when required by the FTC and similar agencies in an investigation. Once again, While I have concerns with the 5 problems areas I addressed, I support your general objective and efforts to discourage illegal business activity.