|Received:||6/28/2006 7:20:00 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:As an IBO affiliated with Quixtar, I appreciate the FTC's desire to prevent illegitimate businesses from growing & potentially harming Quixtar's reputation. However, I disagree with some of the prosposed rules. Quixtar has always promoted fast business growth, & their increasing success has shown that. A 7 day waiting period would only slow down the growth of an IBO's business, which in turn would slow down the rate of profits for Quixtar.com and its hundreds of partner stores. I believe that adequate information is already presented to prospects before registration. In my experience, prospects are invited to an informational open meeting, where they meet other IBOs and view the business plan, presented by someone already at the platinum income level or higher. Disclaimers are made at the beginning of the meeting, informing prospects that they cannot get registered at this time. The refund guarantee is also stated. Literature is also left with the prospects. In my experience as an IBO, prospects are given every opportunity to understand the business plan and see it in action as demonstrated by the team, for them. Multiple opportunities are available for the prospect to get every question answered, with no pressure to register until they feel ready. Many prospects are not concerned with questions and are ready to register immediately, which is why I believe a required waiting period would not be beneficial. Part of what makes this business successful is that it can be individually tailored to meet specific needs and desires for each person; unlike more traditional jobs or businesses, where the income or the opportunities are dictated by a corporation. Providing references and private information of other IBO is also unnecessary, because of the previously mentioned opportunities for the prospect to be introduced to other IBOs. When interviewing for a more traditional job or business, a prospect is not given the private information of their potential bosses or coworkers. To do so in this case would not only be a violation of the privacy of the other IBOs, but is totally unnecessary and pointless. Proof of income I believe also falls into the violation of privacy category. Also, as previously stated, the informational open meeting is presented by an IBO with a proven track record and a steady Quixtar income. At the open meeting, during the presentation of the business plan, the platinum or above IBO also presents the disclaimer that the amounts of income are averages, not guarantees. This is a business that requires hard work, with no minimum or maximum time allotted; this is also made very clear during the informational open meeting. I am an IBO in the LTD Winters Marketing team, and every LTD Winters open meeting in the country is presented just as I have described. This is a business of complete honesty (though not of disclosing personal information, such as addresses and exact income amounts.) At every LTD Winters seminar, the prospect is given however long they wish to ask questions and do research of any kind. Registration is provided only to those individuals who ask for it. In closing, I thank the FTC for continuing to make strides to keep fraudulent business schemes out of our economic system, enabling legitimate direct marketing businesses to flourish. I believe that Quixtar, as well as other legitimate direct marketing businesses, are a valuable and vital part of our country's ecomony, and should be allowed to flourish without restriction. Thank you.