|Received:||7/5/2006 11:05:03 PM|
|Organization:||The Montana Vista Companies|
|Commenter:||M.A. (Tim) Hancock|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:TO: FTC RE: Business Opportunity Rule... As an introduction....I am 54 years old, currently a Contracting Officer for the USDA Forest Service with 30+ years of service. I have a certification & warrant to dispose of US Govt property, primarily national forest timber valued at up to $2 million per contract. I have been a Quixtar Independent Business Owner since its inception in 1999, an Amway Distributor before that. I got involved in the direct sales industry after being approached by a business associate, after much research on Amway Corp, due process I would say. I read the negative, the positive & did my own research & found a reputable company with reputable people involved. We have been at the Quixtar Platinum & later Ruby Level since 1999 & attained the Direct Distributor level in 1998 with Amway. We got started initially to make some extra income to help pay for our children's college. We saw a bigger picture & the opportunity to what has doubled our income as a GS-13 & allowed my wife to give up her job & work our business. My wife was a GS-6 and no longer works for the Government. Our goals are much higher & our retirement is pretty much set with a much better lifestyle & income than we were planning on 10 years ago. 7 DAY WAITING PERIOD: There is no need for this, while people make emotional decisions at times, most people I have registered have given this due process on their own. The are provided printed information (Sales/Marketing Plan)and CDs and web sites to investigate. Most of the new IBOs we have sponsored have taken at least a week on their own and many longer. Some people have already talked to their family and have some people already ready to register when they get started as they all investigated it together. Quixtar has a 180 day buy back policy if they change their mind & Quixtar is quite liberal with returning money on products, even if they used the stuff. This 7 day waiting period is not needed! PROVIDE REFERENCES: Why would we want to provide a list of other IBOs locally? Maybe they know someone they might get involved with who didn't approach them & get involved with them. I can see providing a list of the Line of Sponsorship & letting them talk to those people with an interest in their success. I really don't want someone else talking about my business with my prospect. I also don't want some other IBO without an interest in my success talking about my business. LITIGATION LIST: Simply put..when someone buys a COSTCO/SAMS CLUB membership do they provide a litigation list to them? No & Walmart etal has much more litigation than Quixtar has or will ever have. I don't see the purpose. Lawsuits don't mean anything in a sue crazy society today. EARNINGS DISCLOSURE: The Quixtar SA-4400 is provided with average incomes. And besides when I do business should I also give them my USDA W-2 form? If they ask I will tell them how much money I made & if we have developed a relationship I will show them a 1099 Form if they ask. But a new IBO doesn't have that advantage when they are just getting started. This is added paperwork that is not needed & would serve no purpose. I make more $$ now than my sponsor, so what the sponsoring IBO makes has no bearing on the new IBO's success really. FINANCIAL SUBSTANTIATION: I think that we should provide the SA-4400 to every prospect, but not your financial statement. (See above comment). I show people they can own a legitimate business where others have made substantial income & I tell them this is not a get rich deal, that you will have to work the business to create income. OR they can be a consumer with access to an on-line shopping mall with discounted shopping & the ability to have a small business or a large business depending on their wants & willingness to the work & that I will help them as well as the organization I am a part. HOLD OTHER DIRECT SALES COs TO THE SAME STD AS QUIXTAR AND YOU WON'T NEED A NEW RULE.