|Received:||7/7/2006 12:38:37 PM|
|Organization:||TEAM powered by Quixtar|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To Whom it may concern: My wife and I became IBO's (Independant Business Owners) through Quixtar in September of 2005. Since then we have been activly pursuing the development of our business, and our lives have changed dramatically. The personal growth we have experienced since joining has been amazing and I would not trade the experience for any amount of money that we paid to register as IBO's. I think that anyone joining a networking or direct selling business needs to understand (and it was made clear to my wife and I before joining) that this type of business takes time to develop. It takes a willingness to change and improve yourself. It is not a "get rich quick" business, and it does take work. It is difficult at first to put yourself in front of people (often times complete strangers) and present a business plan. It is hard to change yourself, to gain belief and self confidence in order to sell an idea that is unconventional, which goes against concepts that most of us have learned over time. Unfortunately selling such an idea has been made even more difficult due to the actions of some unscrupulous people. I applaud the FTC for taking action to keep such people from ruining what I believe to be one of the best opportunities in American history, and for attempting to even the playing field for direct market and franchise based organizations However, a few of the key ideas presented in your proposal will directly affect my business in a negative way, and will infringe upon my personal privacy. My comments to these ideas are listed below: 1) I feel that a 7 day waiting period should be removed from the proposal. My reason for this is simple: it goes against the basic premise of selling. Ask any salseperson and they will tell you that closing the deal is the key element in any transaction, and you have to close when the prospect is excited. Making them wait 7 days will drastically decrease the ability to grow my business. Since our business allows people to get their money back if they change their mind, this really just hurts our business. 2) The requirement to provide specific earnings disclosures: When I present this opportunity to anyone, I give them an idea of the earnings they could achieve given a specific level of volume growth in their business. As our business is based on volume sales I expain that these numbers are a generalization and that they are based upon internal surveys of our organization and past earnings of our upline leaders. However if requested by a prospective business owner, we do have an SA-4400 form which is provided by Quixtar which lists the average monthly income of active IBO's withing Quixtar. I feel that this requirement should be removed from the proposal because providing specific earnings disclosures of our upline leaders would be a breach of their privacy (and in addition I have always been taught it is extremely rude to ask to see another persons bank statements). 3) The requirement for financial substantiation: Direct sales / networking based businesses are not your typical type of business. Yes you do sell product, but the true money is made in the growth of the business itself, not in the sales of a single individual. Since every individual will put a different amount of work and effort into growing their business, and some individuals will need to develop their skills more than others, it is unfair to require financial substantiation of income since the very nature of the business is so subjective. 4) The requirement to provide a litigation list: This requirement is simply unfair. Our business, including a starter pack of product is roughly $270 to join. It will not financially ruin anyone. Is a car dealership required to provide a litigation list to every person looking to buy a car built by their company? I would think that would make it very difficult for the salespersons to sell their cars. This item should be removed.