| Comment Number: | 522418-05496 |
| Received: | 7/1/2006 4:27:48 PM |
| Organization: | eFinity |
| Commenter: | Anthony Rizzo |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
To Whom It May Concern, I have been an IBO in the Quixtar (and Amway) corporation for more than 12 years. Although I have not always been profitable, I would not trade my years of involvement with the company as well as my upline organization for anything. Any shortcomings my business has suffered have been the exclusive fault of my own. My upline as well as the company have given me more than I could ever ask for or expect from a business partner. I feel a waiting period of any length will be detrimental to our business. If a potential IBO wants to wait 7 days (or longer) they already have that option. But a decisive person who wants to get started right away should not have that option taken away from them by a governmental agency. Sometimes the work that a new IBO does in the first 7 days with their new upline is what keeps them going and proves to be very profitable. Regarding references, they are already provided IN PERSON when a new IBO attends a business seminar or business meeting. In many cases the new (or potential) IBO does not have to attend anything. They can call their own upline, watch provided DVD's or listen to CD's which explain the business opportunity's benefits, potential as well as limitations. It has been my experience that financial results are never guaranteed (outside of the promise to pay when products are actually sold) and that the actual financial results are better than expected. It seems to be a policy (whether informal or formal I do not know) to under promise and over deliver. I have found this to consistently be the case and it has taught me to exceed the expectations of others not only within my business but also within every aspect of my life. Although we already have a corporate financial disclosure requirement (see the form SA-4400), additional requirements would be unneccessary. They would be burdensome and are already available for the asking. It is my experience that most people are simply not interested in the financial disclosures that we are already required to give them. It is also my experience that giving people more OPTIONS for more information is good, but REQUIRING it is counterproductive. As far as personal financial statements are concerned these can also be counterproductive, not to mention intrusive. New IBO's should NOT base their expectations on the results of others. One person's income in this busines has ABSOLUTELY NOTHING to do with the income of their upline. If their upline is doing very well in this business (after much work and sufficient time) a new IBO may expect more out of themselves and this business opportunity than is realistic. If their upline is not doing well (because of lack of effort, personal skills still developing, etc.) they may limit their vision and not see what they can really do on their own. The general, everyone inclusive, income potential business plan is in my opinion the best way. It is already modest and does not limit (or overblow) a person's vision in this business. And, as mentioned earlier, requiring an IBO to disclose their own personal income from this opportunity is very intrusive. I hope this has helped you in some way to understand our perspective of our business. Thank You