|Received:||7/14/2006 12:07:53 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I like the fact that the FTC is trying to eliminate illegitimate and deceptive direct selling opportunities, while allowing legitimate ones to flourish. Personally, I have been involved with Quixtar since Sept 1999 and the income I've produced in it has been the only income to keep my bills being paid after being laid off from my Engineering job in June 2004. Not only am I thankful for the opportunity, but have seen it able to provide an income while being able to spend more time with my family of five. I believe my future to be bright with Quixtar. I chose to write to you concerning the prosposed rules concerning direct selling organizations in an effort to provide some insight and possible solutions to accomplish the task you have at hand. 1. The proposed 7 day wait period after disclosure. Not only do I believe this to be difficult to enforce, but also ineffective. Some people take several weeks to make a decision, while some take several hours. I have not seen any correlation to success or failure in our business based on the time to make a decision. I know when I made the decsion to pursue the Quixtar opportunity, the money back guarantee made me feel a lot better about starting. I would strongly recommend against a 7 day waiting period. I would recommend forcing all direct selling companies to provide a money back guarantee. This would discourage and eliminate the misleading and illegitimate opportunities. 2. Proposed requirement to provide references seven days prior to registration. This proposal would also be ineffective and borders on invasion of privacy. In eight years as an engineering manager hiring employees, I found the reference lists very predictable. The only people placed on a reference list would always give a favorabable response, and therefore the list lost its effectiveness. It will always be bias. Furthermore, the reality of the reference proposal would result in a list of 10 very positive and trained responses, whether accurate or not. With respect to privacy. While looking for a job, I fell victim to identity theft from the information provided a prospective employer. Providing personal information to almost anyone could very easily enable people to target the people on these reference lists for fraudulent intent, like identity theft. 3. Provide lawsuits, arbitrations,etc to prospects. This proposal is also difficult to enforce and is only harmful to the legitimate opportunities. Currently the internet is already filled with unsubstantiated/false claims about companies. Illegitimate companies would probably not disclose this information concerning them, while legitimate companies would have to disclose accusations regardless of validity. I strongly recommed against providing this type of information. 4. Disclosure for every income claim. This is probably the most unfollowed practice in traditional business today. In employed sales positions today, the claims are always much higher than the average. However, the companies make the claim that a sales person will make the claimed amount only if they perform the sales necessary to make that income. I have yet to encounter a employer that gives average incomes for commissioned employees, yet Quixtar provides average incomes for IBOs whether active or not. I believe all direct selling companies should disclose averages for levels of performance. For example, the average income for Platinum level IBOs is $$$$. This gives a clearer picture to the prospect, that if they are willing to do the work necessary to achieve that level, what compensation they should expect. This would also eliminate the need for disclosing personal financial documents, which is an invasion of privacy as addressed in point 2 above.