| Comment Number: | 522418-09394 |
| Received: | 7/14/2006 1:41:30 PM |
| Organization: | Quixtar Affiliated Independent Business Owner |
| Commenter: | Juan L Sandoval Jr |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Commision, As a Quixtar Affiliated Business Owner(IBO) I generally support the proposed Business Opportunity Rule, with a few exceptions that I wish to address. I have been an IBO for 8 years now. I was shown this opportunity, given all the information I needed to register and begin ownership within 3 days of first seeing the opportunity. This decision has impacted every day of my life for the better. I do support the rule overall, as it will help to eliminate scams and false opportunities that have no merit. With that said, let me address the issues that will not benefit and may hurt prospective business owners. First, the 7 day waiting period. I think this will hurt the prospects. When someone is starting a business opportunity, the excitement and energy they possess the first few days after seeing the opportunity carry the momentum that is the foundation for the next year. If the prospect has to wait, much of that momentum will fade and diminish their income potential for years to come. As for the requirement of references, this is mainly an issue of privacy. I would hate to have my phone ringing at all times of day or night with prospects asking me questions that the person presenting the opportunity to them would gladly answer. Every new IBO in our opportunity is instructed to present any questions they cannot answer to their sponsor/mentor so all questions are answered. Of course, if required to present references, there is the possibility that the prospect will decide to register with the reference which creates a bad situation for all. Next, the litigation list. This will open the door for all business, even traditional, to present a litigation list to everyone including customers. I cannot fathom a business like Wal-Mart having to list all litigation against them at the front door opening them up to more bogus litigation. Any business that is profitable is a target for bogus litigation. A prospect that wants to get rich quick, could see this list and decide to register only to do nothing but file their own litigation against the opportunity. As for the requirement for specific income disclosures. Once again a privacy issue. I have never seen a potential employer disclosing their income as well as executives income to prospective employees as well as the chances of the prospect acheiving the same levels. With our opportunity, we present the income levels possible for all acheivement levels to every prospect. Usually a prospect also is introduced to other IBO's like them that have reached different levels of income and acheivment. Before a prospect registers as an IBO, they must see the average income for those building the business. I believe this also addresses the need for financial substantiation. To close, as I mentioned, I have been an affiliated IBO for 8 years. I have not reached the goals I set upon registering. I still recommend this opportunity to anyone who is willing to do the work. This opportunity has affected every aspect of my life for the better. I hate to see scams and unsubstantiated opportunities, but would hate to see our, or any true opportunties, to be unfairly hindered due to the new rule. Please take my comments into careful consideration as the people out their chasing the American Dream depend on you to make this come true. Thank you, Juan L Sandoval Jr