| Comment Number: | 522418-05919 |
| Received: | 7/4/2006 12:53:56 PM |
| Organization: | Quixtar |
| Commenter: | Scott Bleeker |
| State: | WA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I am a commercial banker and a Quixtar IBO. I have been an IBO for about 5 years. I currently bring in between $600 and $800 per month. When I investigated this opportunity I took about 45 days to review the materials, contact the Better Business Bureau and my State Attorney General's office. I continued to go back to my sponsoring IBO for more information which he provided. I did exhaustive research from my perspective as a commercial banker. I was very satisfied wih this process and joined. The current proposed rules have a worthy goal behind them and with some fine tuning should be a valuable tool in the industry. In regards to the 7 day waiting period: at any bank you can finance the purchase of a six figure home and you only get a three day right of recision. Given that the minimal cost of registering as an IBO is around $50.00, a waiting period to register seem onerous. As a commercial banker doing multi-million dollar deals I am not required to give referrences. Again, given the dollar amounts involved with Quixtar, requiring IBO's to give referrences creates an unlevel playing field respective to other business, such as my bank, and again seem onerous. Listing legal actions against Quixtar: Imagine if Wal-Mart was required to disclose all legal allegations to every potential customer before that customer was allowed to be a customer and make a purchase. Allegations are easily made in our day. Disclosure would not necessarily reveal valuable or pertinant information. Disclosure and substantiation for income claims: Again I look to my role in banking. In commercial banking we don't substantiate anything. In consumer lending on residence, any substantiation is in the form of a generic tri-fold brocheure. In Quixtar I already give more disclosures than in banking. Again, given the dollar amounts involved with Quixtar versus banking, it seems that such additional subtantiation beyond what we already do is onerous. I am very pleased with my experience in Quixtar and the example we set for the industry. My involvement with Quixtar has enhanced my career as a commercial banker by teaching me some of the realities of being a business owner, not just a bank employee. I appreciate the desire of the FTC to create a level playing field in the industry that will protect individual in the market place. I request the proposed rules I mentioned here be edited so that they do not go beyond normal business practices of other industries that have much greater resources and much larger dollar values/consequences involve than Quixtar does. Thank you.