|Received:||7/14/2006 11:26:13 PM|
|Organization:||Independent Business Owner|
|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 many years. My objective is to supplement my retirement income with a few hundred dollars per month extra income. Other than the monetary benefits, I also appreciate the personal growth opportunities a business venture offers me and my wife. I have been aware of purported distorted results that some businesses claim to their prospects. I personally believe that I have never made claims that my business could be a road to riches with little or no work. Quite the contrary, I believe that I fully disclose accurate information to prospects so they can make an informed decision. I am concerned about a number of the provisions of the proposed rule. 1. The seven day waiting period before a prospect could join my business would provide a huge stumbling block to my business. When people make a decision to do something, they need to act immediately on that decision or nothing will ever get done. It appears to me that a waiting period is effective when large sums of money are involved or when a decision can not be reversed. In our business, if a person joins and then wants to quit, we offer a full refund for both the registration fee within the first month provided they notify the company in writing and return any products they have ordered. Notice that the only requirement to enter our business is approximately $45 for registration. There is no requirement to purchase any products. Quixtar has a money back guarantee for not only new business owners, but anyone who purchases their products. With this money back guarantee, there is no need for the waiting period. 2. Re: provide a list of 10 references. I believe providing a list of references is less than helpful. Anyone familiar with such lists know that such lists always contain only those people who would provide positive opinions. Also, there is no way to insure that the people on the list are telling the truth to any prospects that might call them anyway. 3. Re: Provide a list of lawsuits and legal claims involving Quixtar and IBOs. I believe this provision has several problems associated with it. First, with the ease of filing lawsuits, it would encourage competitors to file frivolous lawsuits for the sole effect to require such suits to be mentioned by every business owner in the United States. Secondly, we are independent business owners. What some other independent business owner does has no bearing on how I conduct my business. By listing any lawsuit another business owner is involved with implies to the prospect that I conduct my business the same way. Obviously nothing could be further from the truth. 4. Re: Disclosure regarding every income claim. There are hundreds of possible ways to earn a specific income in this business. I use hypothetical examples of income based on combinations of those possibilities. I include in every presentation certified income averages all active business owners as well as the averages for various achievement levels in the organization. Any more detail than this would be counterproductive as it would overwhelm the prospect with data. 5. Re: provide prospects with personal financial information to substantiate any income claim. The amount of money I make is really immaterial. What is important is that I don’t claim I make income that is incorrect. I personally do not make any claims regarding my personal income. If I did make such claims, I believe the proper place to substantiate them is to an appropriate governmental agency, not to another private person.