|Received:||7/11/2006 10:01:40 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:As a Quixtar IBO some of the regulations you are proposing should be reconsidered. 1. The 7 day wait period before registering is too long.Giving the prospect compliant/company approved literature and accreditations, provides them with enough information to make a wise decision on their behalf. By providing a reasonable cancellation period can provide them time to change their mind (ie. 3 business days like most transactions). If they want more time to decide is fine but do not make it mandatory time length. 2. The IBO references are not needed within the area. The business opportunity is based on individual need or desire. Each direct seller work at his/her own pace and if they do not keep actively involved they will not have accurate info on the company to be a good reference. How can this be fair to the company's reputation if these business owners do not keep informed of any company changes? The references would be more accurate and more efficient if the prospect could follow up on the company's information or background from a FTC approved list of agencies providing sufficient information for the prospect to base a wise decision. Therefore, each prospect can check the Better Business Bureau and/or various legitiment agencies (FTC approved) that monitor business practices before he/she registers knowing they have a reasonable cancellation period. 3. No financial records of the sponsoring IBO should be required to be disclosed to the prospect (this is personal information). This business opportunity is based on individual goals and ambition so therefore there are no guarantees of certain level of income unless proven performance. The IBO is responsible for their own income via commissions based on his/her IBO's performance (figured from company approved pay scale) which is disclosed before registering. The business disclosures should be fair and help the consumer make the right decision for themselves (whether they decide to get into business or not). There should be a fair, standardized, and uncomplicated income disclosures applied to all direct sellers.The disclosures should be very clear and understandable to prevent miscommunication between the FTC and consumers. Granted there are misleading direct sales people but Quixtar provides specific disclosures of conduct rules and regulations that have to be agreed upon when registering as an Independent Business Owner when representing the company to prospects.There should be a simple basic "reasonable" guideline that all direct sales have to be approved by the FTC for all business opportunities to be legitimate. As mentioned above, all prospects should be provided with a list of agencies (FTC approved) to check on the business he/she is considering of starting. This list would provide any company disclosures, accreditations, litigations, references and commissions so the prospect can compare to what they were told by the business representative (if this person misrepresented the information, there should be a place to report him/her to have the company they represent review their procedures and have them removed if needed so that the rest of the "honest" business owners are not punished for the acts of the misrepresentives. Therefore,all the basic direct sales guidelines can not be misconstrued by prospects when FTC provides the list of agencies with the company information. The direct sales opportunity should not be jeopardized by unfair regulations because this opportunity provides an option for families limited to not being able to coordinate an out-of home workplace for income. Working from home is a great opportunity for households to earn extra income (needed today) when staying home with children and employment/income for handicap, etc.Making direct sales a difficult and lengthy process for prospects will only make it difficult for prospects to make a decision which may be their opportunity they have been looking for (keep it simple and understandable).