| Comment Number: | 522418-04990 |
| Received: | 6/29/2006 1:38:39 AM |
| Organization: | Vision I-Commerce |
| Commenter: | Dean Gittings |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom it May Concern, I am a Penn State graduate, owner of a security firm, a restaurant, several real estate rental properties, and a Quixtar Independent Business Owner. Our Quixtar business has been great fun and after a year and a half of consistent effort, we are making over $1000/month consistently. It has been an important income and was crucial recently when our restaurant closed. The business is exactly that, a business, requiring hard work, learning, and risk. I accepted that just as I did in all of my other businesses. We have had great fun, made a lot of friends, and we plan on a great future, with Quixtar playing a large part in our financial future. First, I would like to applaud the FTC's attempt to regulate the industry. The hardest part about this business is overcoming the false negative and bad reputation caused by other illegal and misleading systems. Some help in this area, from an informed and intelligent perspective, will make all of our lives easier and more profitable. When I saw the opportunity, I asked my upline what were the chances of becoming a direct distributor or platinum and he told me less than one half of one percent. That cemented my decision to do the business. It told me it was legitimate because in my experience, it's always about 1/2 of 1% that excel in any field of endeavor. If he had told me that 50% or 25% or 10% or even 5% of people who got into this business made it to that level, I would have known he was lying. He gave me all the of materials and supported me every step of the way. I, in turn, do the same for my people. They need to understand the realities of business and be willing to accept them or they'll just quit anyway and that's a waste of my time and theirs. If they don't have long term success, neither will I, so I am careful and give every new IBO every chance NOT to do the business. The only guarantee that I give a prospect is that they'll have the same chance that I had to achieve success and that I will help them. I also inform them that they have a 6-month money back guarantee on the registration, product sample pack, and any business support materials they may purchase. There is no business opportunity on earth besides ours that offers such a guarantee by the way. I am writing to comment on several items in the proposal that I think would be damaging to our business, and not contribute to the goal of being transparent with prospects: The requirement to provide references: This would violate my privacy and create a lot of work giving references to people in other lines of sponsorship. It would also not be effective because any IBO can find 10 other IBOs who would give a good reference in return for the same favor. It would not accomplish the desired effect. Besides, most organizations have organized team meetings which prospects are encouraged to attend before registering. The requirement to provide a litigation list - You must understand, our business is very inexpensive to start, which is good and bad. ANYONE can get into this business, which means many will get in, expecting it to be easy and then when $100 bills don't start spitting out the D drive of their computers, they quit and say it's a scam. That's our greatest obstacle. Allowing all of those people to hurt us by filing frivolous lawsuits would destroy the entire industry. The requirement for specific earning disclosures: It would be difficult to show the benefits of the business if every other sentence is a disclosure. No business has that kind of requirment and neither should ours. The fact that it's a business should indicate risk. Plus the odds of anyone succeeding are specific to that person and their work ethic, decision making process, and support system. Predicting my odds of success are not the same as the odds of a winning lottery ticket. Thank you, Dean and Yinsi Gittings