Comment Number: 522418-05141
Received: 6/29/2006 7:46:53 PM
Organization: H.A.T. Enterprises
Commenter: Henry Thiele
State: WI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I understand the need for a rule to weed out illegitimate companies and "pyramid-schemes", but I believe the rule as you have it now would have a dramatic impact on legitimate businesses such as mine with Quixtar. Requiring a waiting period after giving a prospect the necessary disclosures would do what? How many people will actually read the disclosures? Giving the disclosures will be enough and with a business such as ours requiring a waiting period could greatly affect profitablity. In 7 days a person could go from highly motivated to completely legarthic because of a buerocratic process that isn't needed. Especially since we have in place a complete satisfaction or your money back gurantee. Second a requirement to provide 10 references of other IBOs is like having someone come into your store but instead of advertising for yourself you advertise your competitors. While the Quixtar business is built with high integration between IBOs in the end we are still competitors to build the strongest business we can. Third, disclosing all litigation over the past ten years regardless of outcome would only invite problems with false claims. But it should be on the prospect to ask for this information. I would have no problem disclosing the information to an interested party, but for many it would only cause unnecessary worries and put a bad spin on a reliable and very real opportunity for many people. Giving people the option to look at the disclosures if they wanted. But to me the providing the disclosures is like asking Walmart to disclose all the litigation that is pending against its suppliers. Fourth, disclosures for income claims. Many income claims we make our based on experience of other IBOs and on a formula based on certain conditions. But since each person controls how much and how hard they work, results vary. Results also vary based on the structure of the business that gets set up, some ways are more profitable than others, but in the end it is the decision of each individual IBO to decide how his/her business develops. I believe a distinction needs to be made between claims and possibities. In closing, my intentions as a Quixtar powered IBO is not to decieve, but to provide opportunities for people. Every time I show someone the business opportunity I'm not only selling the opportunity but also my own integrity and confidence in the system that is in place. Its a shame that this country has gone so far down hill that these things seem not to be enough anymore.