| Comment Number: | 522418-07423 |
| Received: | 7/10/2006 8:01:51 PM |
| Organization: | Baudat Enterprises |
| Commenter: | Janice Baudat |
| State: | AZ |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear FTC: I am an Independent Business Owner (IBO) affliated with Quixtar, Inc. I have been a registered IBO for over 4 years along with my husband Michael. Although we appreciate the efforts that you are making to curb and or eliminate unscrupulous business practices we believe that the proposed FTC rules on our type of business would severely hamper our efforts and those of our team to be successful. We follow strict ethical guidelines set forth by our team leaders and the Quixtar Corporation when we share our business opportunity with others. It typically costs a new person from $130 to $200.00 to register depending on which product kit that they choose. They are able to receive a full refund minus the shipping costs for the products they return if they choose to leave the business within 180 days. I don't see any need for a seven day waiting period for those companies that offer a full refund of fees when someone changes their mind. In fact if everyone had to wait seven days it would incur quite a bit of hardship in scheduling and travel, as well as slowing down the growth of the newest persons business. No one is forced to register before they are ready to do so and everyone is encouraged to get plenty of information, meet the team they will be associated with and do whatever personal research they feel is necessary prior to registration in order to make an informed decision. As far as needing to give the prospect 10 references of business owners, there are plenty of published references that they can verify through the corporation, online or in our profiles of success books. I believe it would be an infringement on mine and others privacy to give out addresses and phone numbers. In our line of sponsorship, we strive to introduce our prospects and/or newly registered people as soon as physically possible to our upline. The newest person would be the most at risk of losing their prospect to another organization with more experience if they had to use them as references. I also think that it would be an infringement of my privacy to have to provide a stranger with my personal financial information. It would be inappropriate for anyone to have to provide this information. However, we do provide typical earnings information to all potential business owners as well as Quixtar company statistics to back that up. As far as having to provide information regarding litigation to the prospective buyer, most of us wouldn't know how to do that or where to begin. If a person wants to know that information, they should be willing to get it themselves and not burden business owners with the responsibilty to get it for them. It is also unfair to have to give information on cases that have no merit, frivolous lawsuits, etc. that should have no meaning but could be miscontrued to contain truth. It would place a huge burden on Quixtar and IBO's to "prove" our cases outside of the courts. I believe that is unfair. I also contend that although the FTC is attempting to weed out the illegitimate businesses by imposing these rules and regulations, the unethical and illegal businesses will simply not comply with the rules and only the good businesses will be penalized and over burdened with regulatory paperwork. Although I believe disclosure is proper and good business practice, we must come up with a solution that doesn't ruin the opportunity for IBO's. Perhaps a centralized FTC run website for Direct Seller & Networking business inquiries listing known fraudulent companies and links to only lawsuits that have been ruled upon would be helpful. Listing the principals of legitimate companies as well as verified informational sites and/or company information phone numbers. Businesses that do not meet Direct Seller Association standards will not be listed and therefore, not officially legitamized and therefore the prospect is forewarned that the company is not necessarily safe to do business with that company. Respectfully, Jan Baudat