|Received:||6/30/2006 11:49:53 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My husband and I have been IBO's since August of "05. We have quickly put together a team of other young ambitious IBO's who share our common goal. We have currently been able to put together a $50-250.00 mnthly income so far. We believe that this business allows us the opportunity to support our financial needs, and actually raise our future family. When our sponsors introduced us to this business, we received all of the information we needed to make an educated decision about this business, and we are so thankful to them for giving us the opportunity to build this business. We duplicate our sponsors by giving any prospects all the information they need. My husband and I have always made it a point to explain to prospects that this is not a get rich quick plan and that although you can get rich much faster here than in many other job like opportunities, you will have to work hard to build a large and profitable business. Typically a prospect spends about $180 to register and then an additional $100/mth or so to run their business after that. We notify every prospect that at any time in the first 6 mths. they can cancel their business ownership and get a refund on all moneys spent. If a prospect of ours had to wait seven days to register it could very much harm their business. Many new IBO's move very fast the first few months, and they would not be able to fully access all of their new products or register anyone underneath them at the rate they desire. This would significantly lower their confidence and belief in themselves, as well as prevent them from becoming profitable quickly. In many experiences that we have had with new IBO's, if you cannot get them moving fairly quickly you are harming them by not being an example as to what power the business holds. I definitely do not believe that the requirement to provide references is respectful to the privacy of other IBO's. Giving out the name, address and phone number of other IBO's or my own for someone else is not a safe practice. When a prospect register's, they are registering to build their own business, not be contacted by thousands of other peoples prospects whom they do not know or trust. In addition to that harm, the practice of giving out references makes it possible for your prospect to go underneath you and register under someone else, which is not fair to the person that did all the work to bring them throught the process. Prospects always have the opportunity to meet other business owners and speak with them at local meetings. Ultimately I believe a list of references would harm everyone, prospects and IBO's alike. Providing a Litigation List would also be harmful to the prospect because many of the Litigations are filed with no merit and simply involve the complaints of sour people who did not wish to make this business work for them. We always explain to prospects that their are many IBO's that make no money and that in the past their have been individuals that did not follow the business standards to build with honesty and integrity. Specific earnings disclosure and financial substantion are taken care of through the prospect screening process. We provide every prospect with a lit pack containing the national average monthly income of IBO's. Additional disclosures during explanations of the business model would just make the presentation awkward and tedious. Our specific local business team shows a list of upline checks, so that any new prospects can see proof of income, but we only show the checks of those IBO's that are willing to open up their financial records, and to require it of everyone would simply hurt the self image of some, while also hurting their credibility with the team. The proof of income is there without requiring documentation from all. I feel this practice would be very innappropriate and rude. Also if someone wants to know what a specific individual makes they typically don't believe in the business system anyways.