| Comment Number: | 522418-09857 |
| Received: | 7/15/2006 11:48:36 AM |
| Organization: | Quixtar |
| Commenter: | Jeanne Kidder |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
We have been IBOs for 1 ½ years. As of now we have accomplished our goal of obtaining 4 regular customers and receiving discounts and monthly checks for the quality products that we purchase on line. Our next goal is to gain 6 IBOs to be on our business team. The Quixtar business fits into our overall lifestyle because it saves us time and mileage that we previously spent shopping. Other benefits of the business are education and competent, honest, helpful professional associates who provide all the help we want or need to build our business to any level we prefer. When we were registered, we received an abundance of information to make an informed decision that this was the right business for us. There is also ongoing education for us to keep us updated. Our future team will receive the same information and education we receive. We inform prospects that the business takes hard work and long term dedication and is not a ‘get rich quick scheme’, and that there are no guarantees of success. Each meeting we attend emphasizes the same information. Our prospects typically spend approximately $250 for registration and optional product pack. They can gain full return of their money if they decide to leave the business. Seven Day Waiting Period: We believe that the 7-day waiting period for registration should be eliminated for opportunities like Quixtar where a prospect can get his money back if not satisfied, thus the rule should state ‘there is a guarantee of reimbursement of money if not satisfied’. The waiting period would serve no benefit for prospects or business owners. It would unnecessarily complicate doing business costing much more financially in travel and communicating with prospects. Prospects would lose valuable education and prospecting time that jump-starts their business as new owners. When we register new business owners or customers, we inform them with Internet Briefings to see if they want to continue investigating the possibility of registering in the business. Then we have a plethora of information including power-point-presentations, brochures, business meetings, house meetings, and most important the individual one-on-one talks, Q & A sessions and phone discussions. A seven-day waiting period would be totally inappropriate for the Quixtar business because of the above information. For a business like Quixtar, there should be a category of Legitimate Business so that scams cannot be compared to such a quality of business. Quixtar is beyond reproach in any area you can question. We have the most comprehensive, well-run business you can find. Give Every Prospect a List of References: The names, addresses and phone numbers of other IBOs in the area are private information and would infringe on the privacy of every IBO whose information was provided to prospects. This requirement should be eliminated. Give Every Prospect a List of all lawsuits, arbitrations and other legal claims for the past 10 years involving Quixtar and its IBOs where the plaintiff alleged fraud, misrepresentation, or unfair trade practices whether or not the accusation was true: This requirement would open up Quixtar and other legitimate companies to false accusations. Meanwhile dishonest companies would simply ignore the rule. This requirement should be eliminated. Make a different disclosure for every income claim. If disclosures are needed, require a simple, standard, easily understood disclosure such as “average monthly gross income for ‘active’ IBOs. Provide prospects with personal financial documents to back up ("substantiate") any income claim. IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies in an agency investigation. We believe that providing every prospect with important information about prior experiences is good for Quixtar and the entire direct selling industry. However, there are less burdensome wa