|Received:||7/14/2006 8:16:25 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar Independent Business Owner for one year. It has been an extremely enjoyable as well as profitable experience. We have achieved strong growth during this time and I feel some of the new proposals will substantially hinder us if implemented. I believe in this industry being regulated but not to the point of elimination. I have never registered an IBO without informing them several times that this is not a "get rich quick" venture. In fact, I tell them quite the opposite. It takes hard work and dedication to be successful and with no short-cuts. I would like to briefly address a few items being considered. No. 1 Requirement of a seven-day waiting period: I feel this would drastically slow-down our growth potential as well as create a huge confusion factor. We already have a six-month money-back guarantee to protect any unsatisfied participants. Anyone who has ever utilized this option knows that with Quixtar it is a simple and absolutely no-hassle situation. This should eliminate the need for any further protection. No. 2 Requirement to provide references: Do car dealers (for example) send consumers to the other dealerships before helping them purchase a new vehicle? That is the same thing we would be doing under this provision. Why would I want to do a complete business and product presentation (2 to 3 hours) and then give the perspective new business owner a list of other IBOs? I certainly don't want a bunch of other IBOs giving out my personal information! Don't we have the same rights to privacy as anybody else? ALL new IBOs come to a meeting with other IBOs before or soon after they get registered. They are strongly encouraged to interact with these other IBOs. No. 3 Requirement to provide "litigation list": This is simply "forced misrepresentation"! Any kind of litigation list is a total misrepresentation of me and/or my business! With the internet and other present-day options, anyone can acquire more than adequate information. No. 4 Requirement for specific earnings disclosures: Totally unrealistic! Completely bogs-down any presentation process. We already are presenting income figures that are so deflated that it is ridiculous! It was my understanding that we did that so that this wasn't even an issue. No. 5 Requirement for financial substantiation: I already share alot of information with prospects about my income from this business and how it effects my Family's lifestyle. If the prospect doesn't believe me, no amount of documentation is going to change his/her mind. I resent the fact that as IBOs we are automatically percieved to be lying about something/everything!