| Comment Number: | 522418-04868 |
| Received: | 6/28/2006 4:49:34 PM |
| Organization: | |
| Commenter: | Joy Hubbard |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I became an Independent Business Owner, powered by Quixtar, in 1999 when I married my husband. Since we began working together to build our independent business, our income from Quixtar has only increased each year. We have been able to pay off much of our debt, buy a house, a nicer car, and send our children to private school. We have also helped at least 6 other Independent Business Owners, that we have taught and helped, retire from their jobs and come home to be with their families full-time. When we register other IBOs, we always ensure they have read all disclosures about our business, including the average gross monthly income of active IBOs. We always emphasize to prospects and current IBOs that this is NOT a get-rich-quick scheme, and requires hard work and effort to succeed. On every audio they receive, there are disclaimers explaining that success is not guaranteed. They only pay a small registration fee (under $100) to register with Quixtar, and all of that money is fully refundable if they change their minds. A seven-day waiting period before prospects can register would be detrimental to our income, as well as the income of other IBOs in our organization. It would require more follow-up visits to actually complete the registration, doubling the time it takes to register new IBOs, and thereby increasing our own costs. It would slow down the amount of time it takes new IBOs to begin earning income, since they would also have to wait 7 days to register new IBOs. Their results would take more time, thus discouraging them from the business. It would also give prospects time to forget the information they were already taught and given, thus making registration less likely. The rule requiring IBOs to give a list of 10 other IBOs locally, for prospects to contact, would seriously endanger our ability to expand our business. The other IBOs might decide to persuade the prospects to register with them instead, thus stealing potential income from us. When prospects register, we always introduce them to other active IBOs in our organization, and they hear many seminars on how these other IBOs feel about our Quixtar opportunity. Giving a document of all litigation in the last ten years would be extremely detrimental to our business. All successful businesses have been pursued legally. An accusation does not equal guilt, but seeing all litigation will give a false impression that our business is illegal or unethical. This is unfair. Employers are not held to the same rules. Any company would have a hard time hiring or recruiting, because all successful ones have spent time defending themselves against false allegations. If we had to make a separate income disclosure for every income example, presentations of the business opportunity would take more time than most people would want to give, in hearing any opportunity. Currently, all prospects are told the average gross monthly income of active IBOs, which protects all IBOs privacy. It violates my privacy to have to reveal my income to others. Also, brand new IBOs who haven't had a chance to begin earning income due to just starting out, would not be able to disclose any income. This does not mean the opportunity provides no income, and would falsely portray to prospects that there is no income potential. Requiring IBOs to give out personal financial statements also violates their privacy and is unnecessary. We always explain to prospects what kind of income we are making and have made, and make it very clear that income varies according to work put into the business. Again, no other businesses are required to reveal their own financial reports to prospective employees or recruits; this would be ridiculous. It is equally ridiculous to require it of business opportunities. Dishonest "opportunities" would just ignore rules and continue to swindle people, while legitimate, honest people would lose business as they follow the new rules.