|Received:||6/28/2006 10:42:22 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO with Quixtar for over 15 years. At times I have worked hard and had success, and other times I have not worked hard at all and only had minimal results. I was informed when I registered that it would be that way. I share this experience with those I register in the business now. They are all told specifically that this is not a "get rich quick" scheme and it will require hard work if they wish to be successful. As there are many people who wish to take advantage of others, I agree with your decision to set specific guidelines for this industry. However, I believe that care needs to be taken so as not to cripple those people who legitimately are working to build their businesses in such a way that does no harm to others. My first concern with your proposal is the 7 day waiting period for registration. This would slow down my ability to grow my business substantially and impact my profitability. It is unnecessary for people registering with Quixtar as the Corporation offers a 100% money back guarantee to anyone who changes their mind about registering. Therefore, there is no risk to the consumer in registering immediately. My second concern is the reference requirement. Privacy is important and many would not like their contact information given out to strangers. In addition, we moved our business to NC where there was no one in our business group "locally". We don't work with people in other Quixtar business groups that aren't linked to us and I would not want my prospects contacting them. They have no interest in my business and may be very happy to try to register those prospects themselves. My prospects are introduced to my team of business associates - either personally, by phone, or through email. I want them to hear from the people who will be helping them with their business, not from some random person who happens to be registered in a different group. Third is your requirement to provide a litigation list. Obviously there are many legitimate claims, but there are many bogus claims as well. If a prospect wants to investigate claims against a company, it is not difficult to do on their own. It would be extremely burdensome to me as an IBO to have to show a list of all the claims against Quixtar and every IBO across the country, not to mention that many would have been filed without merit. Fourth, I think an Earnings Disclosure is important, but the requirement to be so specific is unnecessary. We are careful to explain what the "average active IBO" earns each month, but we also find it is important to explain approximate earning potential for different levels. People want to know what is possible. There are so many factors that can affect the exact amount a person will earn that it would take 4 hours to show a prospect our business plan if required to be so specific. My prospects are informed of the work that is necessary to reach the different income levels. Finally, your requirement for financial substantiation: It is not uncommon for prospects to ask how much money I've made through my Quixtar business. I am happy to answer them in general terms, but how much money I have made is irrelevant to how much they will make. My financial records are my personal business and I shouldn't be forced to disclose them to any private citizen. We are careful to show them clearly how the money is made. I can tell them about my own experience and about the experience of others on the team without opening up my private financial records to show them how I'm doing with the business. Again, that is irrelevant to their own success. I hope these comments are helpful to you in creating a fair and effective rule.