| Comment Number: | 522418-06589 |
| Received: | 7/6/2006 7:55:39 PM |
| Organization: | Robert Reck & Associates |
| Commenter: | Robert Reck |
| State: | IA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife and I have been IBOs for approximately 20 years. During that time we attained the Platinum level. Our next goal is to progress to the Emerald level. We both feel that we have been richly blessed by the help and encouragement of our support team, the opportunity of being able to travel to Orlando, Palm Springs, Hawaii,etc. offered by Quixtar and our upline Executive Diamond, and of course the income generated by our business. When we were registered,the Quixtar opportunity and all that it entailed including how the money was made, plus the avg. amount made by IBOs, was made abundantly clear to us and we and our organization continue to do that. At no time is it ever offered as a get rich quick scheme. We along with our support team have ongoing meetings with registered IBOs to explain to them the work that is involved to be successful in this business. When this proposed rule governing disclosure for direct selling opportunities came to our attention we felt it was timely and definitely needed. However we do have some misgivings about a few of the requirements that have been proposed. There are a few specific issues which we feel would have a negative effect on our business. 1. 7 day waiting period - For business opportunities like Quixtar the need for a 7 day waiting period is unnecessary because we have a money back guarantee if they are not satisfied. Prospects have nothing to lose. 2. List of 10 references - This is plain and simple an infringement on the privacy of every IBO whose information is given to prospects. Plus it puts our personal business in jeopardy by putting our prospect in contact with 10 other IBOs who do not already have a vested interest in that person and might want to register him/her themselves. 3. Disclosures for every income claim - Quixtar already has a simple, standard, disclosure which tells the average monthly gross income for active IBOs which we use every time we show the opportunity.