|Received:||6/28/2006 4:29:43 PM|
|Organization:||Quixtar/Haigh Enterprises, Inc.|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My husband and I have been Quixtar IBO's for 20 years and have achieved the Diamond level. We have enjoyed our business and believe it is a great opportunity to own a business without the risks that go along with traditional business ownership. Our sponsors have been helpful and always truthful and upfront with us. We tell people up front that if they are looking to get rich quick they need to go elsewhere but if they are looking for a business that provides income based on work done, we can help them. We provide information on our business to prospects including the SA-4400 which Quixtar requires us to give out upon presenting the plan and representing incomes. The SA-4400 includes typical IBO earnings and representations for sample businesses. It costs under $150 to register and that includes a product pack of the IBO's choice. All of the money is refundable if the IBO is not satisfied with the process at any time. We tell them upfront that we offer optional training materials and seminars. We then go to work for them helping them to start and run their business at no charge. We believe we are very upfront on everything that will effect the new IBO. A 7-day waiting period is not necessary. No other industry requires a 7-day waiting period and many of them require more money initially, ex. buying any other business or car or house. This would also increase the cost of doing business for the sponsoring IBO. For instance, if working out of town, it would require them to return a second time for the sign-up. It also loses a week's worth of income that could be generated for the new IBO. It would be much better to require a money back guarantee, as we currently offer. At our weekly meetings, we provide an atmosphere where anyone can discuss with anyone there, their experience as an IBO. We use this as our "references" and it puts the reference in control of how much information they give out such as name, address, phone, etc. This provides a controlled atmosphere where people meet in a neutral location like a hotel conference room and does not encourage trying to recruit the prospects there for personal gain. I would consider it an invasion of my privacy if IBO's in my group were required to give out my personal information to prospects that I have not had an opportunity to meet. We run our business from our home and I do not feel comfortable with just anyone having that information. I would not feel comfortable passing out my IBO's information without their permission and their meeting with the prospect for the same reasons. It would be completely disruptive to our business to have to provide a litigation list. Filed cases with no merit would unduly influence prospects and in our litigation happy society, there seem to be lots of frivolous lawsuits filed. Also, every profession has unscrupulous people. Doctors do not have to provide a litigation list to their patients and neither to builders, lawyers, or anyone else. One bad IBO does not mean that everyone is bad and this requirement would hurt the vast majority of IBO's who are operating an honest business. As stated previously, we provide to prospects the SA4400 which lists the sales plan, business earnings for sample businesses, and the average monthly gross income. I don't believe that any additional information is necessary although when a propect asks specifics, we are glad to draw it out for them based on the business sales plan. We do not provide specifics about gross monthly or yearly income. We will describe our lifestyle and provide copies of bonus checks to substantiate claims such as the $10,000 Q-12 bonus check, etc. We believe it would be a gross invasion of our privacy to have to disclose all financial information to prospects. This would also hurt the new IBO who is trying to develop business but has no real income yet to show prospects. We hope the FTC will continue to support the legitimate IBO and not hurt us with unfair, privacy invading requirements.