|Received:||7/7/2006 2:12:48 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My family works good and hard for our accomplishments.I believe I recieved good information when I asked for it. We live in a Society that has FREEDOM, but then there are people that want to CONTROL it like a puppet and that isn't what AMERICA is about We can solve problems and be honest to our fellow men. We shouldn't be required to lay out our Past, but rather it be available upon request. My personal reasoning is, we are always trying to make it better, and the past is not now. You wouldn't want to have someone judge you, based on how you acted 10 years ago when you know that you have grown and learned in some areas since then. Well, that is the same thing as a business. We always strive to do better. Business shouldn't become a business in the first place if they are going to offer dishonesty. Quixtar offers honesty, the individuals (IBO's) have to carry their own weight. Let's be honest, make it work for those working hard at their success in a honest fashion. The Main Problems and Our Proposed Solutions The proposed rule in its present form would create serious problems for every IBO. We have identified what we believe are the five most important problems and are proposing a solution for each: Problem 1: Prospects would have to wait seven days after receiving disclosures before they could register. Solution: Eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied. Problem 2: You would be required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other IBOs in the area – seven days before the prospect registers. This requirement would infringe on the privacy of every IBO whose name, address, and phone number was provided to prospects. It would also penalize the sponsor, who would be required to give his prospect contact information for 10 other IBOs, any of whom might be happy to register the prospect themselves. Solution: Eliminate the requirement to provide 10 references. Problem 3: You would have to give every prospect a list of all lawsuits, arbitrations, and other legal claims for the past 10 years involving Quixtar and its IBOs where the plaintiff alleged fraud, misrepresentation, or unfair trade practices – regardless of whether or not the accusation was true. Among other problems, this requirement would open up Quixtar and other legitimate companies to false accusations. Meanwhile, dishonest companies would simply ignore the rule. Solution: Eliminate the requirement to disclose past litigation. Problem 4: You would have to make a different disclosure for every income claim.This would include any examples you might use during an opportunity presentation to illustrate how the Plan works. Solution: If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs." Problem 5: You would be required to provide prospects with personal financial documents to back up ("substantiate") any income claim. Solution: IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. Again, we believe that providing every prospect with important information about prior experiences is good for Quixtar and the entire direct selling industry. However, there are less burdensome ways to accomplish that goal than the manner set forth in the proposed FTC rule. I thank the FTC for watching out for our American people in the business industry. I am one that doesn't want anything to happen to my successful business. It would effect my family of seven and our future.