|Received:||6/26/2006 12:49:19 PM|
|Organization:||Iacono Marketing Group|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To whom it may concern: I believe some of the items in the new proposal on business opportunities do not help prospects in the least, and would severely hamper our efforts to conduct business; and hurt the economy as a whole. While I am fully in favor of regulating "scams" and illegal business opportunities, the company my business is associated with, Quixtar and its parent company, Alticor have been standards in the direct selling industry for years and have helped countless individuals and the US economy immeasurably. The corporation and its IBOs have been a great asset to the American economy. There are three parts of the proposal that I would specifically like to see eliminated: 1) The seven-day "waiting" period before registration: --Because of our 100% money-back guarantee on registration, there is no danger of the prospect losing any money or making a hasty decision. In my experience, every prospect who has registered with me and later quit the business has received their money back. --I will never register a prospect who is not fully "ready to go" because it would be more work on me and hurt my credibility anyway. --Prospects and IBOs should have the right to register whenever they want, because waiting 7 days seriously hampers momentum and could destroy a new prospect's efforts to make good money right out of the gate. 2) The financial disclosure statement: I have worked for numerous companies in corporate America, and while I did do financial research on the company itself, never once was I allowed to ask anyone in the company for their personal financial records, or ask them how much I would make at a certain level in the company and ask them to back that up with people's personal financial statements. This proposal is an invasion of privacy, and while I do not have a problem with making general statements about finances, I MOST CERTAINLY object to providing prospects with my personal financial records. 3) The Legal Disclosure statements...you've got to be kidding me. If I have to disclose any lawsuit against myself or the Iacono Marketing Group, that is fine; but there is no way we should have to disclose ALL lawsuits against Quixtar or any IBOs nationwide. First of all, it doesn't take any proof or evidence to FILE a lawsuit. Secondly, again, no company I have ever gone to work for in corporate America (Merck pharmaceuticals, Washington Inventory Service, or VWR Intl.) ever disclosed any legal action against themselves during the interview process (despite the fact that companies like Merck are sued all the time). If I had asked for their legal records, I would have been laughed out of the interview process. Of all the rules proposed, this one may be the worst. Finally, let me say that I am a graduate of the United States Military Academy; served 8 years as an officer in the US Army, and am very successful at my day-job as a sales rep for a large science supply company. Never once in my 12 years with my association with Alticor have I been taken advantage of, lied to, or been deceived. I am extremely proud of my association with Quixtar, LTD group, and my upline. The fine people involved in legitimate direct-selling businesses like Quixtar are trying to improve their families qualities of life, and the quality of their team's lives. I am a better citizen, leader, employee, husband, and son because of my association with my upline's organization and my mentors in the Quixtar business. These rules would do nothing but hamper the abilities of legitimate IBOs to conduct business, and would not benefit the prospects at all. We fully disclose all pertinent info to our prospects, and do not want ANYONE to be in business with us who doesn't want to (I already have one job, I don't need another one). Please do the right thing and get the input of direct sellers in the field so you can revise this proposal and make it more beneficial for everyone involved.