| Comment Number: | 522418-06920 |
| Received: | 7/7/2006 11:50:04 PM |
| Organization: | Quixtar |
| Commenter: | Joseph and Carol Koch |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
FTC, I wish to comment regarding the FTC's truly unnecessary and misguided proposals to alter the "Trade Regulation Rule on Business Opportunities" especially pertaining to Quixtar. Generally speaking the FTC's proposals would inhibit business expansion and at the wrong time. To inhibit prospects from registering as IBOs for seven days is ludicrous. This would be unnecessary and demotivating. Quixtar already functions with a 100% satisfaction guarantee and free return on all products. This guarantee also includes IBOs quitting. To expect IBOs to provide a list of 10 references to prospects before they ever see the business overview is senseless. Do other businesses have to do this prior to hiring or taking on Independent Contractors? We continually hold group functions whereby prospective IBOs can obtain information from an assortment of references usually in excess of 10. This absurd requirement would hurt our business in so many ways; i.e. other IBOs could register our prospects, we would lose prospects due to misinformation, private information could be exchanged much of which may not be accurate and most likely fragmented as opposed to comprehensive and documented. Eliminate this absurd requirement to provide references prior to a comprehensive description of the business. Eliminate requiring financial records being disclosed as it's already revealed in both the Marketing Plan and also the brochure THE INDEPENDENT BUSINESS PLAN. According to the Quixtar Code of Ethics we are not to make income claims. Do you know any business with such an ethical, enforced code? The Business Orientation provides prospects with what they'll make if and when they reach a certain PV level. That's a fact. Take the time to examine this. Note also at the bottom of THE INDEPENDENT BUSINESS PLAN the statement; "The Average Monthly Gross Income for "Active" IBOs was $115." It should also point out that "active" is defined as any IBO who bought one product or attended one meeting during a year. Now, that's a fact. So, how does that put in proper perspective the significance of the $115 gross income? Quixtar has already taken care of FTC concerns. The Quixtar Code of Ethics is better and more enforced than the American Psychological Association Code. As a psychologist when I joined, it was what got my initial interest in the business. FTC concerns should be fair, not injurious to our business or confusing to prospective IBOs or Retail Customers. These FTC proposed rules are truly hurtful to our business and will confuse prospects. Is that what the FTC is out to do; naively hurt businesses? We've never seen anything so ludicrous since we joined Amway in 1973. A prospect who is fed an allegation of illegal procedures by Quixtar or it's IBOs can easily check them out within our legal system or even Quixtar's legal Dept. During the ' 80s, Amway did a study of all those who quit the business. They found that 80+% quit because they never started. 75% of the 80% never sponsored anyone. Now, what excuse do you think these folks provided to protect their image? Please eliminate your proposals to destroy our business and take away opportunity from prospects seeking a way to change their lives. When I was in practice, the #1 reason for divorce was lack of money. I could never help them with that issue. Now I can . . . if they're willing to work within our Code of Ethics. So, I suggest the FTC eliminate; *Demanding that prospects register after 7 days of receiving the disclosure document which they can read in a few minutes. *Having to provide every prospect with 10 references 7 days prior to registering. *A listing of all legal allegations, lawsuits, arbitrations and other claims against Quixtar & it's IBOs for the past 10 years. *Making IBOs calculate & make different disclosures for every income claim. It's already in the marketing plan. JK