|Received:||7/11/2006 11:03:14 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:To Whom It May Concern: I’ve been a Quixtar IBO for many years now and would like to share some thoughts regarding the proposed rule 16 CFR Part 437. Number 1: From personal experience registering new IBOs, a 7 day waiting period would be irrelevant for probably half of the IBOs I register as it takes them that long or longer to make a decision anyway. For the remainder who usually register either on the spot or in a day or two, being forced to wait would only serve to diminish initial excitement. Anyone who has buyer’s remorse is also able to get a complete refund of their registration fees long after they have registered. In my personal experience only one person I’ve registered has ever asked for a registration refund and to no longer be an IBO. In this particular case, they had given me a check, and just met them the next day, gave them their check and took back the registration materials. Number 2: I believe requiring prospects to receive contact information from 10 other IBOs is also irrelevant and unwarranted. One reason is that many IBOs I register never express a desire to meet other IBOs prior to becoming involved. They have developed a trust in me and/or the product line and frequently are only interested in availing themselves of the products. Also, prospects who desire to meet other IBOs are encouraged to do so at one of our meetings. They may come to as many meetings as they like before registering. Before I became an IBO, I went to several meetings with my potential upline, so I know what a prospect is going through. So aside from being unnecessary, I think there is a potential pitfall to this provision in that a prospect of any one IBO may decide to register with one of the other IBOs for whom they receive contact information. This could easily create unneeded stress for an entire local organization. Number 3: I believe the provision to provide prospects information about past or current lawsuits against Quixtar or IBOs would serve no purpose. Most prospects don’t care first of all since they understand almost all large corporations have had been subject to lawsuits many of them frivolous. Besides, anyone can find plenty of information on the internet about lawsuits against our business, but I’m not sure how much of it is real. It would also be counterproductive for me as an active IBO to explain the benefits of our business model and then say to the prospect, “Oh, by the way, here’s information about lawsuits against Quixtar.” The key question for the prospect is, “Can I trust Quixtar?” I think they can judge that for themselves just by looking at the companies that Quixtar does business with as well as other literature I always provide. In summary, I could list many more serious concerns for these and the other provisions of the proposed new rule, but I wanted to keep my comments short. I think these rules will pose undue hardships on my ability to build a business and will not aid prospects in their decision making process.