Comment Number: 522418-09203
Received: 7/14/2006 2:50:32 AM
Organization: Quixtar
Commenter: Kristine Sudduth
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I am writing in regard to the proposed FTC rule affecting my Quixtar business. I have been an Independent Business Owner for 15 years with this corporation. The financial benefits have been very significant for our family. My goal in starting this business was to afford tuition to a private school for our young children. Through hard work, and a solid business plan we have achieved that, as well as paying our mortgage, and affording wonderful travel experiences for our family. To think that we have been able to develop a long-term income through a family business , with nominal start-up costs, building primarily with sweat-equity, is phenomenal to me. I must tell you that the proposed rules would seriously impair my ability to continue our business. In particular, I would like to give you feedback on several points: 1) 7 day waiting period. This imposed delay would seriously impair my team's ability to generate momentum and to help our new partners see success as soon as possible. Since there is a money-back clause already built in, i see no reason to delay an IBO from getting started. 2) Providing lists of lawsuits, etc, regardless of their validity, to prospects. My prospects already have access to a similiar listing - they go online to blogs and web postings by disgruntled former IBOs, and they show it to me. I reply that in my experience, if you do the work, and follow the pattern, you will have success. I do not direct my prospect to these websites - I see no advantge for them or me in doing so.The recipe works! In the case of someone who has not done the work, they will not succeed, and it will be easier for them to blame someone else. I am sure there are valid complaints made, after all this is a people business, and people make mistakes. However, I have found in 15 years that people who get in Quixtar with the intent of lying, taking advantage of others, ripping people off, they do not last ! In summary, disclosing all prior legal claims is unfair to me , and unfair and confusing to the prospect. 3) Ten References : I see a problem with this rule, in that the ten references may not be in a business relationship with the prospect, that is, they may be cross line to the prospect. That means that they have no financial or relational interest in the prospect, and they may not take the reference seriously. The rule is also unnecessary because I already make it a point to get my prospects around my team of IBOs so that they can meet their potential teammates. In the case where I am building a new group, and there is not a team yet to meet, it would not be to anyone's advantage to meet IBOs from unrelated lines. I do not want to be called by IBOs outside of my team, and I do not want outside IBOs contacting my team. One potential downside is that the outside reference IBOs would attempt to have a relationship with my prospect, leading to them signing them up in their business. I understand that you must protect the public from scams and illegal pyramids, etc. However, if you look at our rules and regs department, we have many rules in place that protect IBOs and prospects. Look at the SA 4400 - it lists average IBO income at a very low level.. Look at our moneyback guarantee. There is nothing secretive or deceptive about the way I run my business, please do not burden my business with difficult and unneccesary rules. It is very difficult these days for a family to start a business without going into major debt, and burning out on the time requirements. Our Quixtar business was our only option, and I appreciate your support, in recognizing the integrity of our company. Thank you so much! Kristine Sudduth