|Received:||7/6/2006 6:42:08 PM|
|Organization:||RCF And Associates|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am currently President of a Banking Institution in Spokane and my wife is a retired school teacher, now homemaker. We have been qualified Platinums in the Quixtar business affiliated with the World Wide Group (WWG) for four years. Because of the income we have made as Independant Business Owners (IBO), my wife has been able to stay home to raise our four children (no daycare) and we have been able to put our kids in private schools. We have a better marriage, are better American Citizens, are better parents because of the mentorship and educational opportunities we have received since we have been IBO's. In response to the proposed ruling R511993, I feel there are many things that you need to consider in relation to our business. I will address them one point at a time. First, the 7-day waiting period, I do understand why it may seem necessary to impose a waiting period for new prospects, so they don't lose any money from an emotional decision. However, in our business we have a 100% money back guarantee that lasts for 180 days. Meaning if someone does sign-up and decides they no longer want to maintain an IBO membership within the first 180 days, they are immediately refunded by Quixtar for the full amount. Making us wait 7 days to sign-up new prospects, will hurt fast growth, momentum, and initial profit for a new person. Second, Providing References for Prospects: In the corporate world, it is the potential employee that provides the references, not the corporation. In our business, requiring us to provide references to prospects hurts the potential for a new IBO. As you can imagine, someone at my level will be able to provide a much better reference than a person just starting out. This will potentially stunt a new IBO's growth if the prospect, whom the new IBO contacted and built a relationship with, is under the impression that they can shop around for a more qualified person to sponser them. In reality, the only difference may be that the person with the better references may have been involved longer, nothing more. Third, Providing a Litigation List: This seems to be the silliest one on the list because of our sue-happy society. Disclosing all litigation in this case will do nothing but confuse a new prospect and potentially scare them away from a huge income. Since we have been involved as IBO's we have had no legal action taken against us and having to disclose cases we have not been involved in would just not be fair and give the new prospect the wrong idea. Fourth, Specific Earnings Disclosures: As IBO's in the Quixtar/WWG line of sponsership, we already disclose the average income and let people know right from the beginning that this is the average by stating that some people make more and some make less. We also share the WSA4400 and Business Overview (BOV) with all prospects which shows them the numbers in print. Again, having a new IBO disclose his income as compared with a platinum is not equitable, a platinum makes more. Fifth, Requirements of Financial Substantiation: As said above, in our WSA4400 and BOV we disclose all the financial substantiation a new prospect should need to see. This business relies on personal motivation and hard work to make it grow. People can be in the business for years and make little money depending on how hard they are willing to work. We are platinums because we worked hard. Someone may have been an IBO as long as us and chosen not to work hard. By requiring that person to show financial substantiation based on their effort and not the potential of the business may scare off prospects because they don't see the entire picture. I believe that being an IBO through Quixtar is the best financial opportunity around. We are already above board in all that we do when we approach new prospects. Please don't allow your ruling to make our business harder. Use it to stop others that take advantage prospects instead of helping them as we do.