|Received:||7/17/2006 11:52:24 PM|
|Organization:||Access Technologies - A Quixtar affiliated company|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:The past six years I worked as an Independent Business Owner affiliated with the Quixtar company. This business enabled me to meet many goals both within my personal and financial life. It taught me to be a better husband and neighbor by educating me to understand others in a way that was not offered thru my formal education. I was able to better understand time and money management, personality comprehension, as well as identify within myself my true strengths and weaknesses. My next goal is to use what I have learned to help others enrich their lives as mine has been thru the friends and mentors I’ve met in my business. Although they may not be interested in the business side of our program, I am certain that they will benefit daily from those skills as I have. I registered my business after watching my brother’s involvement with Quixtar and his sponsor and support team. I have never met such honest and sincere people, and that was the biggest reason why I decided to get involved. Wealth goes far beyond financial, and this opportunity had it all. There was no pressure for me to join immediately, just a presentation of the facts and experiences of those involved. But now, on to the point of this comment. The list of references is an infringement on the privacy of those who have to disclose their addresses and phone numbers, as well as simply giving those 10 references a chance to sign up your prospect (if in an unethical business). This rule should be eliminated. You do not put references on a resume and therefore it should not be attached to a business card when talking to a prospect. The seven-day waiting period is completely unnecessary to ethical businesses like Quixtar who offer refunds if a prospect is not satisfied. If there must be a waiting period, there should be guidelines that enable companies that meet certain criteria (allow refunds of registration fee, etc) to disregard this rule. I am strongly opposed to giving a prospect a list of all lawsuits, arbitrations, and other legal claims for the past 10 years involving Quixtar and its IBOs where the plaintiff alleged fraud, misrepresentation, or unfair trade practices – regardless of whether or not the accusation was true. Lawsuits are brought daily against all companies and are often of no validity - Pepsi or Wal-Mart do not have a list of their allegations printed on their products and therefore I do not feel I should singled out because I do not choose to spend millions on marketing and advertising. I also disagree on having to make a different disclosure for every income claim. If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." Also, IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation.