| Comment Number: | 522418-06174 |
| Received: | 7/5/2006 3:34:10 PM |
| Organization: | Quixtar |
| Commenter: | Larry Van Buskirk |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My spouse and I have been part of the Quixtar business opportunity since its inception in 1999. We have reached the Diamond level, and enjoy a wonderful lifestyle for our several years of diligent work. I have found this organization to be above reproach in its dealings with ourselves and the public. I strongly recommend that the FTC formalize business practices in our industry, and agree with a majority of the proposed rulings. There are, however a very few that I believe need some refining or rethinking before implementation. 1. The seven-day waiting period would prove truly burdensome in many cases where, after a house meeting, many family members and friends want to join immediately and invite their associates to a meeting. Quixtar has in place an automatic withdrawal and refund feature which effectively gives a new IBO several months to reconsider their decision. I believe that a 30 to 90-day required full refund feature would adequately resolve this issue for all opportunities. 2. The requirement of personal references to my associate IBO's would tend to violate both my and their privacy. We have regular public meetings that allow people to meet other IBO's. I feel that a required list of business references from the sponsoring company would help this disclosure. 3. The listing of all lawsuits in ten years would be extremely onorous for any large company, and would be terribly difficult to enforce for individuals. I recommend reconsideration of the effectiveness of this proposal. 4. Instead of a "full disclosure" of any financial or income reference, which would be incredibly difficult to police, why not have a simple and standardized disclosure by use of an income chart, and a statement such as "The average monthly income of an active IBO is........." 5. Requiring that personal financial documents be shown to prospective associates is impossible to enforce, leaves far too much latitude for personal interpretation, and probably violates all sorts of Privacy Act issues. This one seems almost impractible. Thank you for your diligence in improving the playing field for us all in the industry. I look forward to your continued efforts on this proposal. Larry Van Buskirk