| Comment Number: | 522418-07137 |
| Received: | 7/9/2006 4:04:08 PM |
| Organization: | |
| Commenter: | Pandu Raju |
| State: | CA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife Nisha and myself have been IBOs for the past 11 years. We have been able to replace my wife's income (she used to be a nurse) through Quixtar opportunity and our next goal is to replace my six-figure job income (currently working in the management position in a major electronics company). Quixtar business fits very well with our lifestyle (money and time at the same time). Also, we have developed true friendship with lots of other IBOs and our entire family is involved in this awesome business. When we registered, we received enough information to make an informed decision to register. We provide them with the same kind of information when we register other IBOs. They understand that this is not a get rich quick plan and hard work is required to succeed. Typically new IBOs spend $120 to register and they can get all the money back if they decide to leave the business within 90 days. We are very concerned with proposed rule for US business opportunities that will affect us big time. If we had to wait for seven days and had to talk to references, we would not have registered as Quixtar IBOs and lifestyle would have been average. If we have to provide a list of local IBOs for my prospects, there is a risk that they might register with one of the references instead of me. Also, this rule will violate the privacy. IBOs have plenty of opportunities to meet other IBOs and learn about their experiences before registering and before the cancellation period. As far as the requirement for financial substantiation, we do not do this at my job when we hire new engineers. We do tell the prospects approximately how much we made last year and the impact Quixtar business made on our lifestyle. We are in support of the position that every prospect should have the information needed to make an informed decision but against specific provisions of the FTC proposal that would penalize honest IBOs and cripple our sponsoring efforts. In our view, rule should create a level playing field and provide a reasonable cancellation policy. It should not require a seven-day waiting period before a prospect could register, it should not require IBO references and should not require financial records to be disclosed to prospects. To summarize: Eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get his money back if not satisfied. Eliminate the requirement to provide 10 references. Eliminate the requirement to disclose past litigation. If disclosures are needed, require a simple, standard, easily understood disclosure such as average monthly gross income for active IBOs. 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. Thanks, Pandu Raju