|Received:||7/5/2006 11:57:29 PM|
|Organization:||Quixtar Inc / Arnold Enterprises|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:First I would like to applaud the FTC for taking on the issues raised in the proposal. I am in full support of the intent of the proposal. My experience as an IBO with Quixtar, Inc has been nothing but positive. My background doesn't exactly offer me the opportunity to be a big shot corporate guy. So, the level playing field that companies such as Quixtar provide is crucial for me. The proposed seven day waiting period has good intentions. I don't believe it would severely affect my ability to operate my business. But I'm also not sure it would be effective. There are waiting periods to buy guns and I think we can agree that there are still stupid people that get their hands on them. Someone who is prudent will do no more or less research in 1 day than 7 days - and likewise for someone who is not so prudent. The references requirement is a bit more troubling. My first concern is what a new IBO would do. They have their sponsor - that's one "reference".. But the sponsor may not intimately know that person. In addition, an IBO who had a spotted history would not likely put "un-biased" references on their list. I can see this rule being easily met and serving no good to the consumer by lines of sponsorship simply providing lists of their upline which may or may not even know them. The litigation list requirement is perhaps helpful. For an organization with nothing to hide, it's not a problem. But the ones with something to hide will likely just ignore this rule. IF this rule is enacted, I think it's crucial that it be limited to litigations with a final disposition only, claims filed and withdrawn or thrown out should not be included since they're often frivolous. For the specific income disclosure I again point to my background. The one thing that attracted me to this business was the simplicity. Not being very "scholarly", it would be very difficult to explain complex mathmatical income disclosures. And in the end I would likely confuse the prospect to the point where he did not trust me or the company simply because I couldn't explain each and every income level and how it's attained. A simple disclsure statement that could be provided to the prospect would be helpful, however. The financial substantiation requirement is also very troubling. Again, the intent is pure, but I again worry about the newest IBO. Their disclosure would show $0. Unfortunately for that IBO, the prospect would likely base their ability of success on that IBO's success or lack of success thus far. That undermines the intent of this business in that anyone can succeed and it's entirely up to you. One solution would be for IBO's of various levels - ie Platinum and up be required to substantiate their income to the FTC and a report of averages be provided to prospects. I thank you for your time. I again want to Emphasize my general support of this proposal and encourage you to look at all the issues and how they would affect the newest person trying to start their business. We cannot lose that focus. The intent is pure and I'm excited to see how it pans out. This is governemt in action!