| Comment Number: | 522418-04512 |
| Received: | 6/27/2006 8:44:43 AM |
| Organization: | Kingsway Interactive/ Quixtar-affiliated |
| Commenter: | Paula Marshall |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Hello. I read the proposition of a new rule in Direct-Marketing businesses, "business-opportunity rule." If the rule is enacted, it will destroy my business. While I fully support honesty and integrity in full disclosure to prospects of our direct-marketing business, and support protection of the prospect's interests, I haven't the time or the contacts locally to comply with your exhaustively-detailed and laborious proposition. My upline support team is 2 states away. NOR will any IBO be willing to spend that much time in exhaustive research and presentation. As I and my husband are Independent Business Owners, we do not share our business income information with other Independent Business Owners that are crossline to us, or downline to us. That would be actually harmful to our business, as it may restrict a prospect's potential, should they expect a different result than ours, or give an unfair edge to a crossline competitor. My husband and I are not model IBOs, so by disclosing our personal income, we would restrict a new IBO's self-expectation or potential. Yet, we value our business greatly, and use all the income we gain from the efforts we place. We explain to everyone what the average IBO income is, according to the figures set forth by Quixtar Corp, and we carefully explain to every prospect that continuous time and effore are involved in creating a business, as well as the income potential being in direct proportion to the efforts and learning capabilities they submit. We never rush anyone to start their business, and gie them all the time they wish to research and decide. Also, while we don't use up several days of their life in presenting our business opportunity, which we would need to do if you enact your proposition as law, we always answer, to the best of our abilities, every question a prospect asks. We also supply the prospect with information on ow to contact our support team, and the Quixtar Corporation. We are available by phone to our prospects and team 24 hours a day, and we make available any support materials they ask about. That is adequate. We approach only people who have the mental faculties to make an investigative, formal decision on whether or not to become a team-member, and create their own independent business. We use no persuasive or incentive techniques, other than their potential to have their own home-based business that can increase their income. Should we have to jump through the extensive legal loops you proposed, we'd all have to hire and permanently retain an attorney, and no prospect will have the money or desire to do that. Nor would we. You would kill our business! Please re-think your proposal! It would be far more useful and less expensive for you to mass-advertise to the public a list of which HBB's are legitimate, and for the public to carefully investigate any proposed opportunity, as well as give the hallmarks of a "get-rich-scheme." Thank you. Paula Marshall