| Comment Number: | 522418-06670 |
| Received: | 7/7/2006 12:07:30 AM |
| Organization: | Quixtar |
| Commenter: | Kristi Kreiner |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been an Independent Business Owner through Amway and the Quixtar opportunity for over 14 years and I love it. I have always been impressed by the Quixtar Corporation's professionalism and integrity with the way it conducts and teaches people to conduct business. While I understand the need to protect consumers from fraudulent "business opportunities", I also believe that the proposed rules would severely interfere with the development of my business and other Quixtar IBO's in my organization. I do not believe there should be a requirement for a 7 day waiting period to register, nor a requirement to supply references or financials in support of income claims. Quixtar has a very forgiving process for anyone who may change their mind after registering (which I've never had happen) and they will refund your money for any products purchased within the last 6 months, so you will never end up with a garage full of products you can't sell. I do not believe that prospects who are very eager to get their business started should have to wait for 7 days to do so. Most of the prospects I talk with who want to sign up do so at the same time I show them the business or within a few days after. I think the timing a prospect wants to register should be decided by the prospect, not the FTC. To protect consumers from fraudulant business opportunities, perhaps a recommendation to consumers to thoroughly review business opportunity documents, including the ones approved by the FTC explaining the opportunity, should be made via the FTC's website. I am also opposed to a requirement to provide 10 references of IBO's in the area to a prospect. I have business all over the country, and it would create a hardship on IBO's who live in remote areas to be required to supply names of 10 references of IBO's in their area. As a business is growing, this may not be possible. As a rule I always introduce prospective IBO's to their upline to form that mentor relationship anyway, but they may not live in the same town. Finally, in our business, I think it's unreasonable to require a financial statement to verify income claims. The FTC-approved marketing plan document we give prospects at the time we show them the business supplies enough information for a prospect to see how the income is derived. I consider my personal financial statement my private business, as does any other CEO of a company. Describing to a prospect how the money is made in the business is a basic part of the business presentation anyway. It's no secret in the Quixtar business. Therefore, I think it's reasonable to require that an explanation of all the methods available to earn income through the business is provided to a prospect, but not a requirement of documentation of any particular IBO's income claim. It's the responsibility of the prospect to review the information given and to understand the methods of earning income; to make sure the business makes sense to them before registering. Again, this last comment would be something that the FTC could include on a list of recommendations for consumers on the FTC website, as well. The fine, successful Independent Business Owners I work with in my Quixtar business set the standard for how a business should be run. They are truthful because the truth is good enough! Please do not impose these restrictions on business opportunities, as it will significantly impact the positive way we have been doing business for decades. Please make recommendations to consumers, such as the ones I've described, in order to further help them make good choices in business, not requirements. Thank you for your consideration and time. Kristi Kreiner Quixtar IBO in Phoenix, AZ