|Received:||6/28/2006 3:25:15 PM|
|Organization:||Worldwide Dreambuilders - Quixtar IBO|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar IBO for 9 yrs and have saved money every month since I joined. At the times when I worked the business, I also made a profit. I have also spent 20+ years working for a major corporation, received an MBA in business and currently work in an industry that is regulated but moving towards higher standards - the mortgage industry. So hopefully my comments have merit. Any disclosure or waiting period should be relative to the investment amount. In the mortage industry, we have many disclosures and a 3-day right of rescission (sim. to a waiting period concept) for refinancing closings but this is a MAJOR decision involving thousands of dollars. My Quixtar business franchise cost less than the appraisal on my house. Do I need a waiting period to protect me from the cost of an appraisal order? I have an objection to the financial disclosure because whatever we provide will be misleading. In a job situation or mortgage agreement, the wages or payments are somewhat predictable and disclosure is therefore accurate. As an IBO, my performance dictates my income so it is misleading to pretend that my performance dictates someone else's income. They may make substantially more or substantially less. Any disclosure would be misleading and could limit their income potential. The best disclosure that I can make is to explain the business model including time comittment required as we have always done in our SA4400 business overview form. As far as litigation goes, the requirements should be the same as any business. Do we require other professionals to disclose all litigation before they sell their services to us? Do we require Doctors, Lawyers, Dentists to post in their receptions rooms all the pending complaints against them and anyone else in their professional group? NO - and these professionals can have a significantly more detrimental affect on our lives in the long term. So, it would be unfair to require IBO's to disclose similar information. A similar argument is valid for trade references. Do we require an attorney to provide references from other attorneys with whom they may compete? This is really absurd if you think about it. Now, I must compare this with my 20+ years working for a major corporation (Fortune 100) in management and sales positions. I will tell you that my Quixtar IBO experience has been 1000% more ethical and financially fair to the participants than any position I held in corporate life. For instance, when I was convinced to move from Honolulu to Spokane as The Youngest Branch Manager on the West Coast, I wasn't told that my salary would be below the minimum in the salary range because of my experience level in the business. Nor was I told that I would have to travel on Sundays without additional compensation so I could be available Monday morning at remote offices that reported to me. They didn't tell me that I would have to spend an hour or more each evening responding to corporate emails. They also didn't tell me I would have to give termination notice to my associates even if I didn't agree with the decision to fire them. Was this full disclosure? My experience as a Quixtar IBO has been just the opposite. I've earned more money than they told me and I've never had to enforce a decision I didn't agree with. More importantly, I have a voice in how and when I do busines and when I work harder and smarter, I receive greater income than my efforts in any job or contract situation. In summary, I have the highest respect for the Worldwide Dreambuilders Leadership Team and the Quixtar Group. It's critical that we not regulate or try to fix something that works so well.