| Comment Number: | 522418-06360 |
| Received: | 7/6/2006 1:11:18 AM |
| Organization: | Quixtar |
| Commenter: | Randy Schaffer |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
This proposed rule would gravely affect the income potential of myself and my family in the future in many unfair ways. 1.) Having to wait 7 days after receiving disclosures before a prospect could register is a bad idea. It kills the excitement of the prospect and the momentum building inside of them and allows people who know little or nothing about our business opportunity 7 days to talk them out of what they want to do. I think making it mandatory that a prospect can get a full refund of his money if he is not satisfied is sufficient. 2.) Giving my prospect the names, addresses and phone numbers of 10 IBO's in my area means that there are 10 new people who can steal my prospect from me with me having little or no recourse and is a horrible idea. If my prospect had to sign a legal document prohibiting them from registering into anyone else's business but mine without my express written consent, then I could live with this rule, although I am not sure how I have the right to violate anyone else's privacy by giving out their name, address and phone number without their approval and if they arent willing to grant that approval, that limits my future income in a very bad way as well as limiting the future income potential of a willing and excited prospect who might not be able to register at all. To me, that is very unAmerican and unfair to all involved. 3.) Giving a prospect a list of all the lawsuits, arbitrations or other legal claims for the last 10 years involving Quixtar or its IBO's where the plantiff alleged fraud, misrepresentation or unfair trade practices is a very bad idea. What ever happened to innocent until proven guilty as the standard we use in this country? Any convictions for fraud or unfair trade practices on the part of Quixtar, which there are none to my knowledge, should be provided to a prospect. Any conviction of fraud, misrepresentation or unfair trade practices against an IBO should lead to that IBO losing his business and being sent to jail. I think that is a very fair solution. 4.) Having to make a different disclosure for every income claim is not a good idea or even fair to the prospect. The way I show the business, I tell them if you do this, this and this, this is approxiamately how much money you will make. For example, if you have 10 people in each of 3 communities who each do 300 PV a month and you do 300 PV a month, then you will make about $3,000- $5,000 a month. I tell them specifically that this income amount is based on 10 people in each community averaging 300 PV a month and them averaging 300 PV a month and if they do less than 300 PV they will make less money. If they do considerably less, they will make considerably less money and if all they are doing is registering people and no one is doing very much PV, then they wont make any money at all. I think the idea of disclosing what the "Average IBO" earns each month is really a misrepresentation. We are told that the average active IBO makes approx. $115 a month, but that includes hundreds of thousands of IBO's who decided to put this business under their bed and try to grow a money tree, therefore doing none of the hard work required to make this business work and making no money at all. I think that if you were to take the average income of all IBO's who make a minimum of $100 a month, you would find that the income of the "Average Active IBO" would be significantly higher, maybe 10 to 20 times as much as is listed as what the "Average Active IBO" makes per month. I have been in this business for a little over 3 years and I still have a very modest business and am by no means rich, but that is because I havent put in the necessary hard work it takes to become successful, in part because I had been battling cancer. My business is just starting to grow again as I am starting to put more effort into it. If I never make this a success, it is in no way the fault of Quixtar as they have given me all the tools I need. It is up to me now.