|Received:||7/15/2006 6:53:53 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been an IBO (Independent Business Owner) affiliated with Quixtar since its launch in September of 1999. I began actively developing my business in February of 2002 and reached the 25% level that year. This success allowed my wife to stay home with our daughters for the first years of their lives. Our experience has been extremely rewarding both in business and personal growth. I have always found the disclosure of investment, commitment level, and income potential to be both available and accurate. I currently provide prospects with the required SA4400 from Quixtar which includes the average gross income of all “active” IBOs, as well as specific written details on the cost and content of the optional product pack and recommended training materials and meetings. I’m very specific about the commitments, activities, and investments that were necessary for me to build this business. My prospects clearly understand that there is consistent and prolonged periods of activity necessary to build our business, that this is not a "get rich quick" vehicle, and that there are no guarantees of success. I have my prospects sign the paper detailing this information prior to registering them, indicating their understanding, and their desire to make such commitments. Regarding the proposal of a waiting period, I feel any such period would infringe on the freedoms of an individual desiring to establish and begin building the Quixtar business, and limit their initial success by restricting the timing in which they could help others. These limitations would actually hinder the prospective business owner. As far as a requirement to provide references, any such references would themselves be eligible to register the prospect into their own group. This would be similar to requiring any business owner to send their potential clients to their competition for a personal referral prior to transacting business with the client. Such a requirement may also violate the privacy rights of existing business owners. Having said that, prospects do have the opportunity to meet and converse with existing IBOs prior to registering and any of the optional training sessions. I could go on to discuss the merits of proposals to require disclosure of any litigation related to the Quixtar business (which would only lend temporary credibility to potentially slanderous and fraudulent claimants while causing permanent damage to both existing and prospective IBOs) as well as proposals requiring specific and personal earnings disclosures (which again would violate privacy rights of all existing and future IBOs). The reality is that individuals operating in an illegal, immoral, unethical or deceptive manor would be the least likely to adhere to the proposed regulations. Any such regulations would only serve to hurt those who, presently or in the future, seek to build legitimate businesses in a legal, moral, and ethical manor. I applaud any effort to identify and discourage individuals or operations who deceive or defraud, as such behavior tarnishes the credibility of legitimate businesses and their operators. I strongly oppose, however, and regulations that would infringe on the privacy or freedom of honorable individuals, and hinder their pursuit of success within credible opportunities.