| Comment Number: | 522418-06545 |
| Received: | 7/6/2006 5:04:24 PM |
| Organization: | T & E International |
| Commenter: | John Evans |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear FTC: I have been a Quixtar IBO for over five years and have benefitted immensely from working with the Team personnally and financially. Starting any business is difficult but with Quixtar I have a mentor who is financially free from building his business - no other business offers such help. Of course people find out there is work involved and quit but I was never misinformed about what it would take. It does take the willingness to persevere and believe in yourself and apply the prinicples that others applied who became successful. I got all the information I needed to move forward when I was selected as an IBO. Registration costs between $70 and $130 depending if they opt for a sample product pack. This is basically a risk free opportunity. My comments about the proposed ruling are as follows: 1. WAITING PERIOD. A seven day waiting period is not necessary since this is not a financial obligation where anything is at risk. It's not like an expensive time share or buying a gun...It is a $70 registration fee! 2. REFERENCES. Providing references is also not practicable. Again, what is the risk? I do not nor do I know of anyone who tries to "talk people into this business". I make careful selections based on ambition, character - it makes no sense to talk someone into the business and then devote my time working with a person who is not serious nor suitable. What other business requires references? There is plenty of info available to prospects from other sources. A reference may be overly enthusiastic if he has persevered and been successful or negative if he did nothing. What benefit (objectively) would this provide a prospect? I am the one mentoring him so my view is the only relevant one. 3. LITIGATION LIST. In the age of litigation, it means nothing that someone has filed suit. Frivilous law suits are legend. Besides, there is a faulty description of who the "seller" is. It could involve the entire network. When someone opens a McDonald's does the FTC require disclosure of all law suits - like the woman who was burned by hot coffee?? Law suits are frequently without merit and so is this provision. 4. EARNINGS DISCLOSURE. Some people "join" Quixtar because they want to believe in "get rich quick" no matter what their sponsor says. Then when they are not millionaires in a month they quick yet stay on the books with minimal or no income. Disclosing this is like telling all freshman college students what the grades are for all persons in college. Those who expend effort get good grades and those who don't do not. What benefit is this information. The SA-4400 document already covers income averages. Besides I don't look to select average people and if one asks me what the average IBO earns I will not select him - I DO NOT WANT AVERAGE PEOPLE IN MY BUSINESS. 5. INCOME SUBSTANTIATION. My income from my Quixtar Business and my consulting business is private and no one else's business. It is based on my efforts and in no way does this relate to what someone else can do. Again, the college grades apply. What does telling a freshman what I got on a test have to do with what he will get??? This business is not "we all are equal". Some expend more effort, learn more and earn more. Income is ONE metric but not the only one and out of context there is no point to the disclosure. FINAL COMMENTS. Quixtar is perhaps the best most level playing field business on Earth. I other "psuedo-similar" businesses have abused the genre' of networking businesses, we collectively apologize for them. Penalizing the whole genre' for the abuses of a few is not practical nor moral. As a self-employed business man (in addition to an IBO with Quixtar) I can say the caliber of people and their character and concern for others surpasses all other businesses. It contributes to people being better people, more financially secure and the FTC should do all it can to promote the business not restrict it. Very Truly Yours, John S. Evans III