Comment Number: 522418-04674
Received: 6/27/2006 10:11:52 PM
Organization: Reap communications
Commenter: Pikhelela Chilunga
State: CO
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I would like to share a few brief comments regarding the proposed Business Opportunity Rule. I have been approached with numerous business opportunities, and therefore am pleased with the FTCs desire to prevent any fraud, however I am concerned with some aspects of this proposal and how it will affect my business. As a Quixtar IBO over the past 3 years, I have benefited financially as well as personally through the relationships I have developed. Quixtar has proven to be a tremendous asset in my life. My goal within this next year is to reach the Platinum level and I realize I must develop myself and others in order to achieve this goal. There are just a few areas in which I have concerns. First is the 7-day waiting period. When I was shown the Business Overview, I received adequate information to make an informed decision. In fact, whenever the Business overview is shown each person receives adequate information on account of the standard SA-4400 and BOV (business overview) documents given to each prospective IBO. Furthermore, if at some point after registration the prospect decides this opportunity is not for them they will be fully refunded their registration cost. In view of these, I don't see the benefit of the 7-day waiting period. In regard to requiring the reference list of local IBOs, we are all Individual Business Owners. I guess one can view us as individual franchises of Quixtar. If I had a McDonalds or Starbucks I would not give every customer a list of all the other McDonald's in the area for the simple fact that this would potentially decrease my profitablity. Besides, at our regional meetings prospective IBOs are able to meet hundreds of local IBOs and are able to gain any additional information from the speaker or our upline Platinums. Furthermore, being a single woman I am not comfortable with other IBOs giving my name, address and phone to people I have not met. I am not entirely clear on the language used regarding the litigations over the past 10 years. Does this imply that I would have to provide all litigation involving Quixtar itself, Quixtar and all of its IBOs, or just those involving my business? What if the litigations were not substantiated? I think this section would be an unnecessary impedement to all IBOs. I also have questions regarding the financial substantiation and earnings disclosure. We currently are required to give every prospect an SA-4400 which gives financial information that you at the FTC have approved for our business model. I think that is sufficient. When asked, I tell my prospects my personal monthly income, however I feel that is not necessary to the actual business presentation because they can make more or less depending on their activity. The fact that this is not a get rich quick scheme is made abundantly clear in the presentation due to the fact that it is repeated time and time again that you are the deciding factor. If you choose to do more than you get paid more, if you choose to do less you get paid less. I think requiring me to show my financial earnings is an invasion of my privacy and unneccessary. That is the extent of my concerns at this present time. I do feel like I need to read this again in order to gain a better understanding of what all will be required, so if I have any other concerns I will submit another comment form. Thank you for addressing my concerns. I trust you will come to a decision that keeps honest businesses successful and fraudulent ones off the market