|Received:||6/26/2006 4:58:42 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an Independent Business Owner(IBO) with the Quixtar(Q*) opportunity for almost 4 years now. I’m currently in Platinum qualification and will complete qualification next month (July ’06). I will also be helping at least 1 out of 4 personal IBO’s that I sponspored to reach the 25% level during this time. I’m extremely happy with this great opportunity in that I’m seeing success and also I’m able to help others see success both monetarily and otherwise by the positive relationships we have built with many aspiring IBO’s. The corporation is definitely the most open, honest and easy to deal with corporation I have worked with in all my life. I intend to work this business to the very top and my next immediate goal is to help 3 new businesses achieve 25% level by the end of the coming fiscal year(Emerald), starting September 2006. My children love the associations we go to and they learn so much from these positive environments. This is the best gift I could have given my children in today’s world to build a positive self image and great character. My sponsors are extremely helpful to this day and have always provided me with all the information I needed in starting and running my business and also directed me to the information sources without any hidden agendas. If they did not know something they would take the extra effort to go with me and find the information and the Q* corporation always gave us the information without hesitation, till date. I constantly keep myself abreast of all the information that I need to pass on to my new IBO’s and I have started duplicating my sponsors in every way. I have known from the word go from my sponsors and through personal experience, like any genuine business the Q* business is not a quick rich scheme and requires persistent and consistent effort and I ensure, that is the opening remark I make when I show the opportunity to prospects. I tell them just as there is no guarantee one would get a degree by enrolling in school, there is no guarantee of success in the Q* business just because somebody signed up – It requires work and dedication. While registering an IBO I walk them through the site or the registration from and typically the registration cost is around $120 -130 because I usually recommend they get the product intro pack even though it is not compulsory, because my experience shows people who get to know these products right at the beginning get excited right away and is easier to work with them. However, the choice is always given to them to decide and most often they just take my advise because they trust me. At the time of registration new IBO’s are also informed that there is a money back guarantee associated with the registration and I encourage them talk to the Q* customer service so they have 1st hand information on conditions for money back guarantee what and how much will be re-funded in case they decide not to build the business. 7 Day Waiting Period – While it is a great step by FTC to screen out unscrupulous pyramid schemes the 7 day waiting period for registration I believe is rather unhelpful for genuine businesses like ours. As an IBO I have already spent my valuable time prospecting and educating potential IBO’s on this great opportunity. After all that effort, when the prospect is ready if we are to say they need to wait another 7 days there is a possibility that external factors could wash away this prospects enthusiasm to try something of value even before getting a chance to take it home with him/her. This is just like saying “After a businessman sells me a great product with money back guarantee, when I’m just about to sign the check for it I’m told, I need to wait 7 days before I can buy it” If this scenario is not acceptable to other business models, why penalize our model just because of a few unscrupulous businesses and cause confusion in the prospects mind when he /she has already been educated that there is a money back guarantee on the registration as explained above? Again as an IBO I have to follow up with this prospect after 7 days in effect investing more time and travel for a relationship that was already confirmed. This means loss of time that could have been used in prospecting new IBO’s and helping existing IBO’s with their goals. The financial implications are not necessarily quantifiable but are obviously visible and draining. Also the new IBO will get disillusioned about this rule and may decide not to build this great opportunity just because of this rule which he/she perceives as another hurdle to build this business successfully. The 7 Day rule has no positive impact on the prospect’s ability get more information about the Q* business because whatever information the prospect requests is readily provided to him/her and also he/she is given direct access to all available legitimate sources of information to independently collect the desired information at the time of offering the opportunity. The requirement to provide references: “My question is: If I were to open a MCDonald’s franchise, does McDonald’s tell me that there are other options such as Burger King and others and that I should check them out first before they talk to me?” If not why this rule for the Q* IBO? I’m the one who spent the time and effort to prospect this person. Why should I be asked to turn him out to a competitor? Won’t that be rather suspicious even to the prospect? This will kill all enthusiasm to build the business even for the new prospect. Also does this rule in effect expect me to know information about other IBO’s in the local area? – Why should I? Moreover, I feel rather uncomfortable that other IBO’s in the area will be passing around my personal contact information to people I haven’t even met, people whom I have not done a Qualifying Interview with to see if I want them on my team or not. This rule will definitely be a threat to my personal privacy and information. If the intention of the rule is for the prospect to get more personal feedback on experiences of other IBO’s, this is already being facilitated by me and my sponsor and the team. Before registration I introduce them to other IBO’s personally and let them mingle with other IBO’s freely in business seminar settings, where they meet several IBO’s on their own and get their questions answered. I believe this is more professional than the new proposed rule. Requirement to provide a "Litigation List": This sounds totally ridiculous to me. This is like saying Microsoft or any other major corporation should present all the litigations against it to a prospective “Independent Consultant” before hiring them to that position, or like Walmart asked to do the same before selling any product to a customer. This will lead to pure red tapeism and sounds to me like an effort to scuttle the efforts of ambitious individuals with limited means from building their dreams through an excellent opportunity by corporations who hate our guts. The requirement for specific earnings disclosures: I always lend the FTC approved literature pack to a prospect after the presentation. This gives them at least 24 - 48 hrs to browse through all this information and then I follow up with them to answer any further questions they may have.Further detailed information is always willingly provided to the IBO even after signing andI don’t see the need to give more information during a presentation The requirement for financial substantiation: When I was new I used to tell them the potential of money to be made and the pros and cons along with literature as told above, and then impress upon them I was new and so I have made a small $7.00 check and I would show them that with pride. I then introduce thenm to my sponsor and have him show his bigger check. Now that I make better checks I show them those checks as well. And this what I teach my team of IBO’s. I tell them the intangibles I have got from the business associations as well. However this is my prerogative and I don’t think I should be forced by any law to show a prospect my books and bank balances because this my personal information. After all I pay my taxes and if any relevant agency requires any information they can always get it from me or from their records. In closing, although I welcome an effort to scrutinize businesses so that unscrupulous companies/individuals do not take unsuspecting people for a ride, many of the proposed rules will scuttle the growth of genuine IBO’s in genuine organizations like Quixtar.