|Received:||6/29/2006 11:55:20 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My name is Todd Layne and my wife and myself have been Quixtar IBO’s for 9 years. We started when the business plan was under the Amway Business Plan. In the 9 years that we have been involved, we have never been deceived or misled by anyone in our organization. This proposed ruling, while a good thing to help stop fraudulent businesses, will also cause legitimate businesses to falter. A seven day waiting period: We have never had to push anyone into the business. Our follow-up process takes as long as the prospect needs. The orientation meetings are open to them and they can attend any of them for as long as they want as a prospect at no cost. When I talk to prospects, I explain to them that they are free to do their own research and that they should make an educated decision before moving on to the next step, which for some is the next day, while others take several months. Requirement to provide references: All prospects can speak to any other IBO at any one of the meetings, that the prospect does not have to pay for entry. And the prospect can attend meetings in their area or anyplace else. I would not want any other IBO to give out my personal information to anyone else, would you? Requirement to provide a Litigation List: ALL companies have had cases against them, this is public knowledge. Does IBM or Disney tell their recruiters to tell their prospective employees about all of the cases against them? I am not an attorney and I would not be able to explain the information anyway. Requirement for Specific Earnings Disclosures: I currently use the disclosure in the Quixtar literature, and my prospects are fine with that. All businesses are different, so how many disclosures can there be? Even the McDonalds on the corner has a different earnings that the McDonalds down the street. Requirement for Financial Substantiation: I don’t tell my prospects how much money I make from my business because each business is different, as in the previous paragraph. I do tell my prospects how this business has affected my life and my relationships. My bank account is between myself and the IRS. Do you tell other people how much you make? Again, while this proposal will help to put a stop to fraudulant businesses, the legitimate businesses will also suffer. Quixtar has had a great track record, as can be seen by our affiliations with major corporations and governements. The FTC should investigate the industry, but to put too many restraints will only hurt it.