| Comment Number: | 522418-07283 |
| Received: | 7/10/2006 11:07:54 AM |
| Organization: | Quixtar |
| Commenter: | William Shearer |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: Response to Proposed FTC Rule Changes I have been building my business powered by Quixtar for the past 11 years. We have attained the Q12 level for the past 4 years and are currently moving on to Ruby and Emerald in the next year. Long term goals would be Double Diamond in the next 5 years. This is our primary source of income as we do not have jobs. My experience has been that what I saw 11 years ago was exciting but the business is 1000 times better today and what was shown financially has always been exceeded as we reached each level. We have maintained this principle of under promising new prospects and over delievering. It takes personal effort to succeed and it is not a 'get rich scheme'. The Quixtar model is a level playing field for anyone who is willing to work the business. A great opportunity for approx. $200 to get started and this is refundable for 6 months. Same goes for any product purchases. Regarding your proposed changes: I support reasonable business disclosures that are fair and help consumers make wise choices. These rules should apply to all Direct Sales organizations equally and hopefully will weed out the illegal schemes that give a bad name to all players in Direct Sales. Specific comments on the proposals as written are - 1.Should create a level playing field by requiring clear, simple, and standardized income disclosures that appply to all direct sales. 2.Should provide a reasonable cancellational policy. 3.Should not require a seven day waiting period before a prospect could register. Point two on cancellation covers the prospect. 4.Should not require IBO references be provided to prospects or disclosure of past litigation. 5.Should not require financial records to be disclosed to prospects. An approved business model that is shown should cover this clearly example: we use a 6-4-2 model showing potential income levels and disclose that the 'average Active IBO makes $115/month'. I consider this full disclosure on financial aspects of the business model. We are former professionals in the working field (management and counseling) and have treated our own business with high ethics and integrity. We are in business for the long term and not just to make some money. We have a positive impact on people, families and children when they join our business group. That is a responsibility that we accept and take seriously. I am available for further details if you require more input. Yes I support consistent rules that apply to all businesses but rules that are not restrictive of free enterprise. Yours turly William Shearer