|Received:||7/6/2006 3:36:04 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:For the past five years I have been an IBO with Quixtar. Before registering with Quixtar, I was given ample resources (BBB, websites, and literature pack) to investigate the opportunity, and these resources are also shared with all potential business associates. I also work closely with potential IBO's to answer any questions, educate them on a business plan that is not a "Get Rich Quick" process and explain the purpose of a start-up fee (Approximately $180) that is money back guaranteed from Quixtar. I have a few concerns with the proposed rules that are listed below. 7-Day Waiting Period seems too excessive and would not provide much benefit to prospects. This would cause missed bonuses, decrease business growth and cause a loss of earned income. Since I work closely with all individuals from exposure of the opportunity to business start-up to ensure this is the best decision for the prospect, a 7-day waiting period rule is only another step to cause confusion and bureaucracy. Also, the money back guarantee eliminates the need for a waiting time. The requirement to provide references seems to be a violation of privacy of existing IBO’s. This rule could also add an element to worry about non-ethical business owners that may convince someone to join another team. Prospects have ample opportunity to meet fellow business owners before starting a business and get proper references for the opportunity. Requiring a “Litigation List” seems unfair to any business. Based on the interpretation of the proposed rule, any claim against Quixtar, valid or invalid, settled or pending, current or past, must be disclosed to the prospect. If a claim has no merit, why should it be disclosed? Specific guidelines should be established if litigation is shared. A requirement for specific earnings disclosures is already FTC approved with Quixtar. This rule would inhibit IBO’s from sharing the potential income with prospects without earning statements from individuals who may not wish to share that information. The requirement for financial substantiation may cause IBO’s to curtail the amount of income produced in Quixtar. Sharing select financial records may be appropriate for a specific bonus, but divulging one’s income tax information is personal. I would feel very uncomfortable with sharing that knowledge with anyone. I understand the need for rules and regulations. However, these rules and regulations should not be designed to inhibit the practice of fair trade by individuals who abide by the rules and regulations set by the FTC. Quixtar has met and exceeded current standards and will continue to meet the standards in the future. If other direct marketing businesses were expected to abide in the practices Quixtar follows, the need to create more rules and regulation might decrease.