|Received:||6/30/2006 2:27:28 PM|
|Organization:||Pinnacle Systems, Inc.|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar IBO for 7 Years. I have worked very hard to build a strong and profitable business. My goal is to develope a team of successfull IBOs that all achieve their goals. We are not just busines partners we are close friends and family. Our business if very forthcoming with information needed to make an intelligent decision regarding registration. When we register anyone they are always provided FTC approved income representations and examples. Every understands that this is a business that requires time money and effort to be successful. It is not a "Get Rich Quick Deal". To register with our team people will usually invest about $200 to $300, which includes the Quixtar registration, insurance, publications, and optional product packs . All of this is refundable. The creation of a 7 day waiting period would be exremely counter productive to the growth of our business. Individuals that would be very successful and be on the fast track would be stalled. People that are ready to go right now may loose their enthusiasm and get caught up in other things, thus stealing the opportuntiy away from them. Every new IBO is given SA4400 and other approved materials as well as access to several web sites that are designed to answer any questions they may have. They also know that their fees are refundable if they change their mind. This rule would be devistating to the profitability of our business. A Requirement to provide references to me would be detrimental to the business for privacy reasons. Please know that the first thing we do when someone is interested in the business is to get them meeting other IBOs. A rule requiring such references is not needed. We encourage prospects to seek information from creditable sources such as the Better Business Bureau and Attorney General. Having to provide disclosures of all cases ever filed against quixtar or affiliated IBO organizations would be difficult and misleading. The Requirement for specific earnings disclosures is also not needed. We use specific examples with FTC approved numbers in our SA-4400. We never over promise but provide corporate and FTC approved averages. As far as substantiating personal financial incomes, I will show a show checks if asked. I try not to rely on personal income clams. The compensation plan gives examples that show if the organization is built in this fashon then the income will be this. A rule to provide personal income documnetation would infringe on privacy. Our policy is not to promise anything. Thank you for considering my comments.