|Received:||7/3/2006 12:47:32 AM|
|Organization:||Quixtar Business Owner--JBK & Associates|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO with Quixtar for 10 plus yrs. I enjoy the income,travel,friendship & education. The flexability is great.My sponsors provided an excellent overview of the business opportunity and answered questions before I registered. When I sponsor people, I review the information 2-3 times before they register &answer questions. I tell them no guarentees, hard work is required & not a "get rich quick" business. I also give them this information in written format. Prospects spend about $200 to get registered, which includes about $140 of consumable products. All of the money is 100% refundable under our 100% money back guarentee. I once had a prospect register and two weeks later changed her mind and she received all of her money back without any difficulty from Quixtar. I am proud to be associated with the Quixtar name. I would like to share some concerns re the proposed Trade Regulations Rules. First, re requiring a 7 day waiting period would negatively affect my prospects. Many prospects decide to register and place an order immediately, so to start receiving business benefits. They are anxious to start building the business and sharing the great opportunity with their family and friends. Having a 7 day wait period would delay their ability to start making money. They already have the information and can get 100% of their money back if they change their mind later; therfore a 7 day wait period has no benefit for a Quixtar business owner. A second concern is providing references. I would be giving my prospect IBO names and they may choose to register with someone else after I've done all the initail contacting and education. I also think this validates my provacy to have my personal information given out. Prospects have several opportunities to meet other IBO's while attending educational and business opportunity meetings with me. My practice is to introduce the prospect to as many other IBO's as I can at these meetings. I think they have adequate exposure to other successful business owners. My third concern is a "Litagation List" . This rule would not really give the prospect valid informations since any perosn can file a law suit for any reason reagrdless of validity. I personally am aware of lawsuits that were filed for the sole purpose to get money from the defendant by hoping they would be given the money to drop the case. This serves no purpose and would not provide any merit to a new IBO. Fourth, is the requirement for Specific Earning Disclosure. My business support materials clearly identify average monthly gross incomes and I openly share this information with the prospect thru "The Independent Business Ownership Plan" -#SA4400. This clearly identifies average yearly incomes at various levels in the business. Additional information would only add confusion and would be clumsy and of no benefit. The final concern is in regard to the proposed rule for financial substantiation. Having to share my personal information from my Quixtar business could easily be misleading. Everyone has different amounts of time to spend with their business and different ambition levels that will affect their growth and profitability. Also as a past owner of a traditional business, I know that you must first invest more time & money to get a business up & running. Sharing financial information could be very misleading. Everyone 's business develops at different levels and profitabiltiy varies. Currently I never share dollar amounts in re to my business, but I share personal benefits like educational opportunities and the changes in my lifestyle since I became an IBO. I again feel that having to share my personal financial information relating to my Quixtar business would be a violation of my privacy., I feel that this would be an inappropriate requirement. Thanks for allowing me the opportunity to share my concerns and thank you for your time in reviewing them.