Comment Number: 522418-08798
Received: 7/13/2006 1:45:39 PM
Organization: Felber Organization - Quixtar
Commenter: Sondra Kraus
State: WI
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

My family and I are eternally grateful that we can be involved with a teaching/mentoring organization that uses Quixtar as a supply company and business opportunity. The reason we are involved in our own independent business using Quixtar is: As a family with two working parents, we cannot see making it financially without creating income in addition to our job income to support us and our children as we get older. It gives us hope that we can provide for our children and that as we reach retirement age we don't have to be a burden to our children or society. We believe the newly proposed rule is necessary to help create a level playing field by requiring clear, simple and standardized income disclosures that apply to all direct sellers. We believe the new rule should provide a reasonable cancellation policy. However, we believe the new rule should NOT require a 7-day waiting period before a prospect could register. Our prospects generally have as much time as they want to research information we give them as well as many websites and other info they want to access. We encourage them to come to briefings where they can meet other successful business owners and ask them any questions they choose. When they decide to register, it is because they are comfortable with the information they have received and that they trust us as sponsors. Once we sponsor them, it is our responsibility to help them be successful at whatever level they choose. We also do not believe that IBO references should be required to be provided to prospects. Anybody getting involved with others in business have a personal responsibility to talk to others successful in that field and to ask questions. Requiring references will cause more work and phone time on the part of IBO's who are already busy building an organization. Further, any successful organization provides plenty of opportunity for new prospects to meet other successful business owners before they register. Also, it is extremely cumbersome and negative to require disclosure of past litigation. Most of this information is available if people choose to look for it. Most traditional businesses have much litigation; but patrons are not handed a list of prior litigation before walking into or using an establishment. I believe this is discriminatory to our industry and that other channels of information are available if a prospect wanted to learn of past litigation. Financial records should never be required to be disclosed to prospects. Same with traditional businesses. Unless capital is being invested, and there is risk of serious financial loss, it is unnecessary and infringes on other's privacy to require that financial records be disclosed to prospects. However, I believe if a prospect asks to see a compensation or bonus check, that it is a fair question and it should be provided, but not REQUIRED by the new rule. The Quixtar legal department has done a wonderful job of providing infomation and disclosure on all important areas. They have also helped our organization design an accurate, easy to understand form that explains compensation in a concise, accurate way. We believe all documents providing income/compensation disclosures should be reviewed and approved by the FTC to protect against fraudulent claims. In closing, if the new rule makes it too cumbersome for a prospect to review and make a decision, it will hurt our industry. We have personally witnessed the lives of many hundreds of couples and singles be changed in a positive way both financially and personally through this vehicle, and to restrict it unduly will be a strike against the very fiber this country was founded on...free enterprise. Thank you for considering our recommendations carefully. Regards, Sondra Kraus