|Received:||7/12/2006 4:43:40 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:in support of the position that every prospect should have the information needed to make an informed decision but against specific provisions of the FTC proposal that would penalize honest IBOs and cripple their sponsoring efforts. (1) Begin With Your Personal Experience Start your comment with a short description of your Quixtar experience: I have been an IBO for 10 months. I have been able to meet goals such as leaders club and Executive leaders club. My next goal as an IBO is to start a second team. My Quixtar business keeps me and my spouse active overall. The benefit other than income is the time spent with my family and new found friends from this business. When I was registered, I received enough information to make an informed decision about whether to register, and also was given a site to get more information if needed after making the decision to become an IBO. When sponsoring others, I provide them with the same kind of information that I received upon signing up. I make it very clear to new prospects that the Quixtar business opportunity is not a "get rich quick" plan, that hard work is required, and that there are no guarantees of success. My prospects typically spend anywhere from 52 to 495 dollars to register, this is due to the fact that the product pack is optional. If a new IBO decides to leave the business within 120 days they will receive all for there (100%) money back. (2) Address Specific Issues Following are specific issues related to the proposed rule. If there are any that are particularly relevant to how you run your business, consider focusing on those issues. You can use the language below as a guide but be sure to put your discussion into your own words – that is very important The requirement of a 7-day waiting period: How would your independent business be affected if prospects had to wait seven days before registering? I feel that this would hinder all of our time, due to the amount that would be spent on registration. What benefits (if any) would a seven-day wait provide for prospects? I don’t see any benefits at all on a seven day waiting period. What costs or burdens would a seven-day waiting period impose on you as an IBO? The costs would be the same. The burden would be having to do more paper work and more contact time instead of helping a new IBO to start there own business. How would it affect the profitability of your business? I believe it would slow it down tremendously. How would it affect the value of the Quixtar opportunity to your prospects if, after registering, they in turn had to wait seven days or more before they could register their friends and family? I believe this would slow it down to a snails pace dramatically, while missing (slow the process) out on all that Quixtar has to offer and in turn affecting the ability to earn income with their Quixtar businesses. Describe a specific or typical example when you register a prospect as an IBO. What information do they receive about the business, and how? The information received upon becoming a new IBO comes If they decide a Quixtar business is not for them, how can they get their money back? By contacting Quixtar via e-mail of phone and request a refund. It’s that easy no questions asked. How would a seven-day waiting period affect the prospect's knowledge of the Quixtar opportunity? I believe the seven-day wait would just prolong the beginning of the learning process, especially when new IBO’s are excited to get moving on there new business because they are now told to wait. I’m sure you have been told hurry up and wait, and how does that make you feel? The requirement to provide references: How would it affect you if you were required to provide a list of local IBO’s for your prospects to contact before they decide to register? I believe it would hinder my business substantially. Is there a risk that your prospect might register with one of the references instead of you? I can see this happing and I don’t believe that be fair How do you feel about a rule requiring you to let other IBO’s give your name, address, and phone number to their prospects? I don’t think that it would be right to give out my personal information. Would that violate your privacy? yes Do your prospects usually meet other IBO’s in your group when they register? Yes they do. We have home meetings which bring us all together. Explain how this works and how a prospect or a new IBO can meet other IBO’s and learn about their experiences. Again as I said it’s all about team work and helping each other. Give specific examples. For instance, having a home meeting with the apprentice team, we would all bring new people in together and explain the business form each of our own aspects. Requirement to provide a "Litigation List": The disclosure document would require a list of all litigation involving the seller, its key personnel, and its representatives that deal with "misrepresentation, fraud, securities law violations, or unfair or deceptive practices with the past 10 years." Would the following pose a problem for you? The proposal doesn't adequately cover what a "seller" is, meaning that IBOs may have to list all litigation involving Quixtar itself as well as the entire IBO force across the country. This would also not be limited to cases found against the seller but even filed cases with no merit. The requirement for specific earnings disclosures: What disclosures and explanations about the income potential of a Quixtar business do you share with prospects today (such as the average monthly gross income, SA-4400, etc.)? We as IBO’s cover the initial profits in small amount, giving an over view of the larger profits that can be made. How meaningful do you believe the additional detail required by the proposed FTC rule would be? I only see this proposed FTC ruling as a hindrance to us as IBO’s trying to establish a long term business. How would it affect your business if you were required to make a separate disclosure for every example you used in explaining the income potential of a Quixtar business to a prospect? I believe this would take a 40 minute plan as shown now and make it a long and drawn out process. The requirement for financial substantiation: What kind of information do you provide your prospects about your personal income from your Quixtar business? For example, do you tell them approximately how much you made with your Quixtar business last month or last fiscal year? Do you describe the impact your Quixtar business has made on your lifestyle? How would you feel if the FTC required you to offer prospects the financial records necessary to substantiate your Quixtar income? Would this be appropriate? Inappropriate? Why?