|Received:||7/9/2006 3:48:21 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been Quixtar IBOs since its inception in 1999. This business model is quite appealling to us because of the financial rewards it offers, as well as the flexibility to integrate our business activities into an already busy lifestyle, and the low overhead costs to begin and operate this business. When we were investigating this business as a financial opportunity, we received ample written information regarding the financial potential and risks of this business model. We were cautioned that this is not a "get rich quick" opportunity and that success in this business, like any business, is based on hard work, training, and commitment. We were also informed by our business team leaders that integrity in business was a standard which needed to be followed, not only for our success, but to ensure the positive reputation of our team and other Quixtar business owners. High integrity is reflected in the way we do business. When we talk with prospective new business partners, we never pressure them to join our team. That is a decision they must make based on the written, web information, and information they can obtain firsthand by talking with other business owners at our weekly business meetings or at monthly business seminars. Some folks take weeks to decide. Some are very decisive and, because of the low risk and low start up cost will register in a few days. A 7 day mandatory waiting period is truly not needed because people who change their minds after registering can get their money back. (Something which DOES NOT happen with traditional businesses.) On the subject of providing written references, I do not think that is needed. We do that already as part of our registration process; we allow the prospects to meet and talk with existing IBOs in person. That method allows us to protect the existing IBOs right to privacy, and still gives the prospect the opportunity to have a dialog with others who are involved in our business venture. Regarding the point involving the substantiation of income, each prospect receives information re. the average earnings for IBOs at various achievement levels. They can meet and talk with people at those achievement levels to assess whether they feel they are capable of reaching such incomes. Just like in the rest of our economy, what one person is already making is no guarantee that I will make that same amount. Give me a number that reflects the average for a group of people so I can have a better grasp of the earning potential. To sum up my thoughts, we are already operating in an ethical manner to inform and educate prospective new IBOs to help them in making the decision which is right for them re. our business model. Your existing proposed ruling would impose major burdens on IBOs in legitmate direct selling groups who already operate with high integrity. I trust you at the FTC will continue to work toward a solution to shut down bogus business opportunities that try to imitate legitimate business models. I hope you can design a ruling which is uniform across the direct selling industry that does not penalize or hinder honest entrepreneurs. Thank your for listening to my thoughts.