|Received:||7/12/2006 8:18:26 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I would like to comment on the above proposed rule. I am an independent business owner with Quixtar.com, I joined the corporation in the spring of 1999. My Quixtar business has impacted by life in a very positive fashion and allowed me access to business mentors who have increased by business knowledge while helping me have a modest finanacial gain. When I registered my mentor answered all my questions before I completed my registration. Also I had 30 days to obtain a complete refund. Our entire organization works on the same principle. We are trained to give our prospects all the information they want, by using two methods. We introduce them to other team members and give them extensive take home materials to complete their due diligance. I make sure they know this is a business that requires work. No one is going to drop unearned money into their accounts. Registration ranges from $75.00 to $250.00 depending how many products they want to purchase. The registration cost ($45.00) is refundable for 30 days, all product purchases are refundable for 180 days. If the rule to require a 7 day waiting period is adopted it would be very negative for my business. About half my business registers within 2-3 days of our conversation, they then repeat the process with their business. The average age for us is 30-35, they expect a much faster pace for business. We market an online real time internet site. If the 7 day period were in effect we would be perceived as stogey and behind the times. We do not directly handle the money associated with registration or purchasing, it is all online directly with the corporation. If they change their minds they can call the 800 number or go online to request a refund. Shipping is fully refunded also. The requirement to provide references would be a violation to every independent business owner in my personal group. We are not in charge of their individual business. Our prospects have the opportunity to meet other business owners at regular meetings. The purpose of the meetings are for prospects to ask questions of other business owners, but also protect the person who brought the prospect from having them register with someone else. We all understand the privacy and integrity issues. Also we provide telephone numers for the corporation and the prospects have to opportunity to log onto and check out the internet site. We take this issue very seriously. We only want to work with people who are serious about working with us. If we were dishonset in any way our own future would be at stake with each new business owner. The requirement to disclose litigation does not adequately explain who the seller is, is that the Quixtar site itself or purhaps the Sony Corporation who supplies a TV for sale on the site, or the person who shows a new person how to order toothpaste? How would an average independent business owner from Bellevue Washington satisfy that requirement. Would all the paperwork put my part-time business completly out of business? The requirement for specific earning disclosure and financial substation falls into the same catagory. The Quixtar corporation publishes how much an average business makes at each level and how those figures are calculated(SA-4400) Our training provides each prospect with those publications during the investigation process. But if I had to open all my personal finances to every prospect, that would be like each person having the requirement to show your paycheck stub to the grocery store mananger in order to buy groceries. We are very forthcoming with our prospects on how income is generated without having to show them our personal financial statements. Try getting the same information from any employer for each of their employees. My final comment is that I applaud the FTC for taking the steps to weed out bogus businesses but those regulations can be written so legimate business will not be handicapped in how they do business. Thank you for your time.