|Received:||7/14/2006 4:58:59 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Thank you for the opportunity to comment on your proposed rule making. I believe the intent of proposed ruling is good but I have some concerns about specific parts of the ruling. I have been an Independent Business Owner working through Quixtar's business model for more than 10 years. I have always found their business ethics to be impeccable and we have always been taught to maintain the highest standards when recruiting new members. I felt that I was given enough information to make a wise decision when I started my business. In the same context, I believe that we provide more than enough information for prospects to make a decision that is best for them. We clearly teach that this is not a get rich quick opportunity, but a legitimate business that will take time and effort to build. I do not support the idea of a seven day waiting period. (We do not pressure people to sign up in the first seven days anyway, and we encourage them to check us out before making any kind of decision). In some instances a seven day waiting period would significantly hender our business. For instance, when working with someone that lives a significant distance from your home, it could require you to make several additional trips to get their business started properly. This would significantly increase my and their cost of doing business. Again, from personal experience, I do not believe a seven day waiting period would be as beneficial to new prospects as strongly enforced buy back guarantee. I do not support the idea of requiring references be given to new prospects. In our business, prospects are introduced to many people already in our business. This is one of the strongest belief builders that we have - the credibility of other business owners in the Quixtar system. However, if your ruling requires business references, it would mean that those business owners that I provide as a reference will probably receive a huge influx of phone calls to check references. Since we are independent business owners, and we typically work from home, this influx of phone calls would become a major nuisance to existing business owners. We encourage prospects to meet existing business owners and ask questions. Also, if a prospect were given a list of 10 phone numbers and told they were references I don't think they would value the opinion of those references, since they are just another stranger on the other end of the phone. I don't think we should provide a litigation list. I'm not sure where this would stop - meaning, will myself and my business possibly be judged by what someone on the other side of the country did and which I had no control over?. We want our business to be ethical, but in our society, anyone can sue for anything and it doesn't have to be legitimate. I think a better alternative would be a site provided by you that lists businesses that have had judgements ruled against them and that have acted in a less than ethical manor. Do we require any other profession to list all the legal claims (valid or not) filed against it and/or anyone involved in that profession? I am against personal earnings disclosure. We have a document approved by the FTC that shows the income potential for each level of business structed in a pre-defined format. The document also shows the average income made by business owners in our business. Again, we do not require that incomes of every person in a corporation be provided to someone interviewing for a traditional job. When someone applies for a job at your office, would you want to show them your personal income statement? We have a good business and are associated with a company (Quixtar) that has been above reproach. I would like to see unethical, get rich quick schemes be eliminated. I think this can be done without harming us by requiring strong, enforceable buy-back clauses and low start up cost, with no heavy front end loaded businesses. Thank you.