|Received:||7/1/2006 2:01:01 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO in Quixtar since 1989. It has been a great experience. We (my wife and I) have made a profit each year and have become friends with many excellent businessmen with a high degree of character. I got alot of information before signing up, knew that the business would take work and knew that I had no real risk as it cost me about $100 to get started and everything was totally money back guaranteed. Today the business is better than ever and still has 100% money back guarantee on all registration expenses ($50-$150) including products. I have never been lied to or misled. I wish I could say that about my other business (Veterinary Medicine). Although I have not become financially independant from the Quixtar business I have benefited financially and through a personal growth program (World Wide Group) my relationships and traditional business have all improved. I am glad that the FTC wants to regulate these businesses. It will help the legitimate ones but I would suggest several changes to the proposed law: 1. Eliminate the waiting period. Since there is 100% money back guarantee if not satisfied. This would adversly effect profitablility of everyone, delaying growth and not necessarily give the prospect more info. 2. Eliminate the requirement to provide a list of references. It would infringe on the privacy of those people and may cause his prospect to sign on with one of the other IBOs on the list. 3.Eliminate the requirement for specific earning disclosures. We provide information like the average monthly gross income of an active IBO and other detailed information of the profits on a SA4400 form. More detail would be confusing and overwhelming to the prospect. If they want more information we will always provide it. 4. Eliminate the need to provide a Litigation List. The proposal doesn't adequately cover what a seller is, meaning that IBO's may have to list all the litigation involving Quixtar itself as well as the entire IBO force across the country. This would not be limited to cases found against the seller but even filed cases with no merit. 5. The Requirement for Financial Substantiation. I describe the effect of the Quixtar business on my life to the prospect. IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. Thank you for looking into this issue. I can only summarize and tell you that this business has helped me in just about all the areas of my life. I believe it is important to regulate these businesses to stop the bad ones but the regulation should not hamper the organizations which are building their businesses with integrity and benefitting many families as well as this great country through our free enterprise system. Thank you for your attention, Craig Adler D.V.M.