|Received:||6/27/2006 10:18:45 PM|
|Organization:||Britt Worldwide-Crowe Organization|
|State:||Not in the US|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
|Attachment:||522418-04675.pdf Download Adobe Reader|
Comments:My wife and I have been an IBO for 11 years. We have been able to hit the Silver Producer Level so far. Our next goal is to qualify as a Platinum IBO. The Quixtar business fits into our lifestyle as an integral part. The benfits are legitimate business ownership, leadership training and skills, and being able to be a "Prosumer" (consumer/producer) in the marketplace. When we registered, we received enough information to make an informed decision about whether to register. When we register others, we provide them with the same kind of information to make an informed decision. Prospects understand that the Quixtar business opportunity is not a "get rich quick" plan, that hard work is required, and that there are no guarantees of success, because we make it clear by telling them so. A prospect typically pays approximately $60 to register without any product intro packs, and 100% of it is refundable if they decide to leave the business. My independent business would be hindered by the 7 day waitng period, because new IBO"s would have to wait longer to be able to expand their networks, which would hinder fast growth. Besides Quixtar.com as previously stated has a 100% money back guarantee if not satisfied for any reason. With the requirement to list 10 references, there would be a chance of unethical IBO's trying to steal prospects away from the initial IBO who made the contact with the prospect. That would be unfair and it would violate my right to privacy. Plus my prospects are encouraged to meet other IBO's in an Open Meeting setting (where the sales and marketing plan is shown) who are of similar or different work backgrounds and there already is a chance for them to question other IBO's after the presentations. The requirement to provide a "Litigation List" involving the seller doesn't adequately cover what a "seller" is and that would mean I would have to list all litigation involving Quixtar itself as well as the entire IBO force across the country. This would also not be limited to cases found against the seller but even filed cases with no merit. If requirement for specific earnings disclosures are needed we would like to point to the fact that Quixtar.com already has a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." Lastly the requirement to provide prospects with personal financial documents to back up or substantiate any income claim is inappropriate. We feel that 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. In an attachment I have added there is information on what is provided and available to prospective IBO's.