Comment Number: 522418-05878
Received: 7/4/2006 2:12:55 AM
Organization: quixtar IBO
Commenter: Allen Sudduth
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I have been an Independent Business Owner affiliated with the Quixtar Corporation since it's inception in 1999. For the eight years prior to that, our business agreement was with the Amway Corp. The income we derived from this business has sent both of our children to a school of our choosing, and continues to pay for college tuition. We have found it to be a valuable asset in our lives, one that we have worked hard for, and continue to work, in order to create long-term assets for ourselves and our family. From our first exposure to this business, it has been our experience that there was, and is, a very high level of integrity involved. If a long-term income is based on long-term relationships, then the only way to protect and expand that is through dealing with honesty and integrity with other people. We have been successful because we understood it would take work to build our business, and our success would depend on our effort, combined with a strong support team. We teach this to anyone either looking at or getting started with us. There are no guarantees except that we will show up and help anyone who wants it. There are several areas of this proposed rule that are very disturbing to me, and I think they pose a legitimate threat to my business. Since we already have the abilitiy for new IBO's who have a change of heart to cancel their action and recieve a full refund with no questions asked, the 7-day waiting period would only hurt growth, especially for the new person. The percentage of people who changed their minds in my personal business last year was less than 1%. On the other hand, IBO's who were able to get a quick start and take action right away are significantly more profitable as a result. My suggestion would be to eliminate the waiting period! Regarding the "10 references". Our goal, as soon as possible is to introduce a prospect or new IBO to the 10 people who will actually be serving as their support team. When we began, the foundation of our business was laid in great part through this support. 15 years later, that same support is still there. Since the "10 references" would have no vested interest, I see the rule as potentially very subversive, and should NOT be included in the final version. In regards to the listing of all lawsuits, especially regardless of the merit of the suit, all I can say is that "there are more lawyers than there are good cases". Bad Idea. There were two types of disclosures addressed in the proposed rule; I agree that a simple, easily understood disclosure is neccesary. I have always made that clear in my presentations, and ,in fact, use conservative numbers in my illustrations, and teach others to do the same. The second disclosure was most disturbing to me. Being required to disclose my personal income to anyone who asks violates a basic principal of privacy. I do, of course, keep substantiation for any claims I have made, and have, by choice, even shown my 1099's to selected people. But that should be one's choice. I do support the FTC's efforts in this area, as there are many business that DO NOT police themselves sufficiently, and DO take advantage of unsuspecting people. I feel our business is very transparent, with every opportunity to get credible information already available to anyone who wants to find it. I feel very strongly that this proposal, as it stands, would do more harm than good, and would have grave financial consequences for my associates and myself. I do encourage the Commission to draft a fair and equitable rule that rewards those already in compliance, while regulating those that may not be operating with full integrity. I have invested 15 years in this business, and it is has produced an income that will serve us for the rest of our lives. Please proceed with caution and sensitivity for those who may follow. Thank you for making this forum available to us.Keep up the good work. Sincerely, Allen Sudduth Santa Rosa, CA 7/3/06