|Received:||7/11/2006 6:55:48 PM|
|Organization:||Legacy Business Group|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Gentlemen, as an independent business owner affiliated with the Quixtar Corporation, I would like to respond to the business changes the FTC is proposing. I have been an IBO since 1994, and as an IBO, have always provided ample information on the corporation to prospective IBO's including the SA4400 form. Quixtar also provides a number of web sites including www.thisbiznow.com for IBO's to obtain valuable information on the corporation and the opportunity. Since the current registration cost is approx. $325, I'd like to compare the impact of your income and referral recommendations to a private auto repair shop. I believe the new IBO registration cost is approximate to the average auto repair cost. As such, it would be prohibitive for the FTC to ask any auto repair shop to provide a list of satisfied customers and to disclose income from operations to prospective customers. Additionally, it would be just as unfair for the FTC to ask auto shop owners to hold all checks for 7 days while the auto owner confirms their satisfaction with the repair that was just completed. Likewise, providing a list of recently registered IBO's, providing an income statement, or delaying the registration process could severly impact the profitability of any Quixtar IBO's business! The current business plan has NO guarantee of any income amount as the profitability of any Quixtar business is entirely dependent on the activity of the IBO. All disclosures are based on averages - average founder platinum, average founder emerald, etc. Those averages are based on consolidated information by the Quixtar Corporation and are available to the public on a number of sites including www.thisbiznow.com. All perspective IBO's are encouraged to review all pertninent informaton prior to registration. Placing that responsibility on the individual IBO would be cost prohibitive (to the individual IBO) and could also lead to inconsistent and unsubstantiated results. While I think the issue of disclosure is valid, I think it is most appropriate to ask the corporation, not the individual IBO to provide the information. The Quixtar Corporation will continue to be the best source for disclosures - not the individual IBO.