Comment Number: 522418-07367
Received: 7/10/2006 4:07:27 PM
Organization: Quickstar/Team
Commenter: Christopher Mazza
State: CT
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I write to you to discuss the proposed rule change which would affect all independent business owners and how it would impact my business association with Quickstar. I have been associated with Quickstar/Team of Connecticut for approximately 4 months. My business line is the first of its kind in my state with Team. I have found that the business opportunity was explained very thoroughly and openly too me. The start up costs in total was less than 250 dollars, all voluntary aspects of any costs where explained in great detail. I was reassured that even should I leave the business I would still recoup about 1/2 of the costs due to being able to return products that I may not have been satisfied with. As we were a new business in Connecticut, Team sent 2 knowledgeable representatives from the Midwest at their own expense to make sure all aspects of the business were presented accurately. One of my early concerns was that I didn't want to become involved in a pyramid scheme. Quickstar representatives were very forthright in declaring that this was not a get rich quick opportunity and that average business development was 3 to 5 years. Additionally, the opportunity to exceed income levels of my "upline" broke another of the usual pyramid traps. So far I would say I am totally satisfied with my business relationship with Quickstar. My concerns with the proposed business rule change is that many aspects while well intentioned will have an overly burdensome impact on my business. I applaud the basic premise of the rule and urge the following aspects be review for change. First, the requirement to wait 7 days after initial disclosure I feel is overly burdensome. Many times we set up business meetings by renting out space at conference centers/hotels. By creating artificial timelines this would require additional costs for rental applications. Second, the requirement to provide a list of 10 alternate IBO's while well intentioned to provide more feedback could cause many persons that I spend time and money recruiting to become registered under a referenced IBO. The impact to my business would be significant. When new IBO's are registered they traditional meet many associated IBO's at business meetings that all are encouraged to attend. Normally, during the first introduction meeting, the prospect IBO would meet many persons already in the business line. We like to have several different persons on hand to answer questions. Additionally, it would be a violation of my privacy to give blanket approval for all IBOs to have access to my home address and phone numbers. I should retain the ability to control all personal information. The requirement to disclose all litigation to prospects is overly burdensome. The rule does not differentiate between merit less lawsuits or ones where the "seller" was found against. Additionally, the definition of seller doesn't cover all aspects of the business. While I work for Team, I might be required to provide information on competing organizations that have been found to be fraudulent. This would impact my business by misrepresentation. While I provide information voluntarily to business prospects about income potential, it would be inappropriate to require that I disclose financial documents. It would create additional cost to produce and would violate my privacy. Often when describing income potential we speak in general terms. What a traditional business can expect with certain guild lines met. Again, Team/Quickstar was very upfront that this was not a get rich quick scheme and most business requires 3 to 5 years of hard work. Thank you for taking the time to read my correspondence, Christopher Mazza