|Received:||7/15/2006 12:39:49 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My husband and I have been independent business owners (IBO's) affiliated with Amway and then Quixtar since 1980. We started our business so that I could be a full-time Mom instead of a nurse, and so that my husband could eventually leave teaching and have a greater earning potential than teaching allowed. I never returned to work and he left teaching after 3 years to work with our church. We have been full time since 2000. Our business has given us much more than income; it's been a positive environment to raise a family and we are rich with many friends and family who partner with us. We are concerned about proposed changes that we believe would seriously hamper our business: 1)The 7-day waiting period is unnecessary with 100% money-back guarantee on the opportunity as well as products. This requirement should be eliminated for a legitimate business like Quixtar. 2)The requirement to give a list of "references" is an infringement of IBO privacy. When we started our business and even beforehand, we were introduced to individuals from a variety of backgrounds and were able to ask them any question we wanted about the business, and about why they, in their particular profession, would put time and effort into building a Quixtar business. We do the same still today; meeting others from similar backgrounds is a powerful way to lend credibility to our business. We have nothing to hide but to give others' private information to someone is inappropriate and could result in someone else sponsoring the individual we introduced to the business. That would be unfair. We strive to have INFORMED IBO's, ones who make intelligent business decisions about starting their own business with Quixtar. This requirement should be eliminated. 3) The requirement to provide a "litigation list" would be very unfair. Because every IBO is independent and no one is refused who wants to start a business, disgruntled or dishonest individuals could cause and have caused problems for everyone; cases w/o merit could be brought out and this would unfairly damage everyone. Past litigation against Quixtar itself or against other IBO's may have nothing to do with the rest of the business owners. It could burden honest, hard-working IBO's with potentially false accusations and fraudulent companies would probably just ignore the requirement. This requirement should be eliminated. 4)The requirement for specific earnings disclosures would make the explanation of our business too complicated as there are so many variables. Quixtar has always cautioned IBO's against inflated earning potentials. The "average monthly gross income" is already stated in our literature. How much an individual can earn from their Quixtar business has always depended on how hard someone is willing to work their business; in our business we were always taught and have taught that there is "no free lunch", that it is not a get-rich-quick business, but that the time and effort required is worth it. You must treat it like a business to succeed. 5)The requirement for pesonal financial substantiation is a gross violation of privacy. It is no one's business (except the IRS) how much money someone makes in their Quixtar business OR in their regular job or profession. As inappropriate as it would be to ask someone how much money they make in a year at their job, it is equally inappropriate to ask the question about their Quixtar business. Instead we speak about what kind of a difference the income has made in our lives; what have we been able to do that we couldn't before, or the impact on our lifestyle. This is very appropriate, and Quixtar has made available the average income of the various levels in the business. We already make this available to those who want it. We appreciate the opportunity to voice our opinions on this matter and hope that you will take our view serious. They are not made lightly. Thank you.