|Received:||7/13/2006 1:46:26 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Thank you for the opportunity to share our perspective on the Proposed Rule. We appreciate the work being done to protect against fraud and unethical schemes. We have been Independent Business Owners affiliated with Quixtar since July 2001. The income we've earned has made a great impact on our family, especially since my primary income, self-employment in construction, fluctuates over the year. We are proud to be part of this business model where we can help others in many ways, not only financially. We are dedicated as a family and as an organization to accountability and integrity in our conduct, and we commit to giving each prospect the best chance for success by being open and honest and following the Rules of Conduct set forth by Quixtar. Regarding some specific aspects to the Proposed Rule we have the following views: - Eliminate the 7 day waiting period, especially for business models with a money back guarantee, like Quixtar. - Eliminate a requirement to provide 10 references, as this would infringe on the privacy of those business owners, any of whom might sponsor that prospect instead. - Eliminate the requirement to disclose past litigation. This will unnecessarily burden the business owner, since any legitimate (versus alleged) cases are already disclosed by the Better Business Bureau for any inquirer. In your efforts to "get the bad guys," this portion of the rule would negatively affect legitimate businesses while dishonest businesses would ignore this requirement altogether. - Eliminate the need for separate disclosures of specific earnings by having one simple, standard disclosure, similar to what we already use in Quixtar, called "the average mothly income for active IBOs". - Eliminate the requirement for financial substantiation. We have found the income potential disclosed by Quixtar to be very accurate and realistic and we have no problem substantiating any income we've earned. We believe that a business owner should be able, but not required, to disclose personal financial documents unless required by the FTC or another agency during an investigation. We commonly find that the new business owner sponsors at a higher rate initially, compared to later on, and it takes time to build up a network (which generates the higher income). Therefore, this portion of the rule would negatively affect the new business owner who has only begun. Thank you again for your attention and we know that all your hard work is going to produce a rule that will prevent deception and fraud while continuing to protect the many business opportunities that have made a profound impact on free enterprise in America.