|Received:||7/4/2006 12:19:32 PM|
|Organization:||Leadership Team Development|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been a part of the direct marketing industry for 18 years, with Amway and Quixtar. I left medical school and an engineering position because of the success this business model provided. As a result of my decision, I have been able to create business and employ several people which obviously stimulates the economy. We now run a good family business for which we are very thankful and appreciative. We hope that the business will be a viable option in the future for our four children if they choose to pursue this type of business. Our business has provided the opportunity to spend more time together as a family which has strengthened our family unit. When we started our business we were aware that there was no guarantee of income or success. Today it is no different. We are very clear with people that it is not a "get rich quick scheme" and that it will require time, some investment, and effort just like any other business. I realize that not everyone in our industry is that up front, but in working with Quixtar Corp., I have seen a very conservative approach on their part when it comes to income claims and the such. I would hope that the FTC is sensitive enough to the fact that you cannot "lump" all direct marketing businesses together. I know that there is deception out in the marketplace as we have to deal with it also. I have dedicated 18 years of my life to providing a fair and equitable opportunity for people to help their families and the proposed rules would adversely affect our business. As to the 7 day wait period, it is not necessary when you provide a money back guarantee if the new Independent Business Owner is not satisfied. I don't think that is case with other business industries such as franchises. In regards to the 10 "references", it is an invasion of privacy to give that information to "prospects" who may never get started and now have that information. In addition, a new IBO doesn't have 10 references when he/she gets started so they could not get their business growing and are out of business before they even start. I don't think that reflects a fair market, free enterprise system which we have in the US. As to the legal "allegations" against Quixtar and its IBOs for the past 10 years. First, I am not an employee of Quixtar nor am I associated with every IBO who deals with Quixtar, so why would it make sense to associate MY business with all other IBOs and their legal allegations if there are any. We are all independent and the purpose of this purposed rule seems only to spread negative impressions and hurt our opportunity to grow our business legitimately. As to the income claim issues, Quixtar requires us to show the average income of an active IBO. We are very up front with the fact that there is no guarantee of profit or false expectation of profit for the new IBO. I am against disclosing my income to a person that I do not know. It is none of there business. I don't believe that a CEO or a manager of a company is required to tell a potential employee at a job interview their income, so why would it be right to make a rule for an IBO to disclose personal information. In all, I agree with the idea of having standards and trying to give the prospect true and accurate information for them to make an intelligent decision. I believe that our organization and Quixtar Inc. already do our best to achieve the objective that you are wanting to accomplish, and the proposed rules would adversely affect our potential to grow our businesses. Once again, let's not "lump" all direct marketing businesses under one roof. There are legitimate, honest people who work, and have worked, very hard for what they have. Thank you for considering my thoughts on the Proposed Rules.