|Received:||7/12/2006 9:17:54 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife and I have been Quixtar IBO's since inception in Sept 1999. At that time, my wife was working full time as an Office Manager. Since December 2004, my wife was able to stop working and become a full-time Mother for our son. We do not intend for my wife to return to work as our Quixtar Business is bringing in enough income monthly to allow her the choice to stay a full-time Mother. Our next goal is to replace my full-time job income as an Account Executive for a large Mortgage Lending Company, so that I too can be a full-time Father and husband, and have the time to pursue my personal goals outside of working for someone else. The personal development program that is provided to us thru our relationship with Quixtar has been tremendous and has helped our marriage, as well as prepared us to be better parents for our son. Our goal is to create a muti-million dollar Marketing Business thru our affiliation with Quixtar; one that will allow us financial independence, and more importantly, allow us to pass this Business onto our Son when he becomes 18. When we registered as Independent Business Owners, we believe that we received sufficient information and disclosures for us to make an informed and eductaed decision. The Compensation Plan was clearly explained and the average income generated at each level of success was clearly disclosed. We continue to provide this same information to prospects that we share this Business Opportunity with as we look to bring them on as Business Associates on our Team. We clearly explain that the compensation plan is not a get rich quick road to success and that there is work, focus and commitment required. We do explain that one gets out of this Business what they put in and that there are no guarantees. The registration cost to become and IBO with Quixtar is approx $45 for the registration information and then an additional $115 for the product kit which introduces new IBO's to some of our exclusive products. Therefore the total cost of registering as an IBO is around $160 plus sales tax. The cost of the product pack is fully refundable up to a year if a new IBO decides not to pursue the opportunity. I believe that this is 100% fair. My concerns about the propsed rule are as follows: 1) A 7-day waiting period will only slow down the registration process and therefore impact income and sales. Since enough information is already provided to a prospect before they register as an IBO, then there is no need for them to wait 7 days. 2) The requirement to provide references is another rule that would slow the process un-necessarily and therefore impact our income negatively. A potential IBO, in several instances will naturally meet more than ten currently registered IBO's in their local area prior to getting registered as an IBO. Our reason for doing this is so that the new prospective IBO can see the support that they will have locally, as well as be able to ask any questions of any IBO that they may deem necessary to make a decision. 3) The requirement to provide a litigation list is also un-necessary, as litigation lawsuits are already public information. If this is to be a requirement for Direct Selling, then it should be a requirement Corporations to provide this information to potential new employees as they go thru their interview process. Our current process which allows a prospective IBO to perform due diligence if they are seriously considering our Business Opportunity is more than adequate. 4) The requirement for specific earnings disclosures is already provided by Quixtar to all prospective IBO before they register, This document is called an SA4400 and is already an FTC approved document for disclosing the average income levels at different levels of success. If we are expected to make disclosures for every income example in Direct Selling, then Corporations should also be required to make similar disclosures when they quote potential income during their interview process.