| Comment Number: | 522418-10196 |
| Received: | 7/15/2006 10:17:00 PM |
| Organization: | 28745 Avondale |
| Commenter: | Iris Michelini |
| State: | MI |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been an IBO in the Quixtar business for about 10 years. We've registered many people in the business and also have loyal customers. It has never been difficult to register anyone in the business because the business system and the products sell themselves. We've always been upfront with prospects and give them enough information to make an informed, competent decision. Simultaneously, however, we inform them that ours is not a "get rich quick" business. It takes diligence and effort to succeed. Because of the effort and time involved to introduce prospects to the opportunity, we believe that it is unfair to require us to send our prospects to other IBO's as references and/orexpect prospects to wait 7 days to register. Such practices are subliminal suggestions that something about our business is unethical or fraudulent. Also, I believe that having an eager prospect wait 7 days to register, thwarts his/her enthusiasm; it suggests that they as new IBO's will have the same unfortunate set of circumstances with the prospects. This dilemma could be very discouraging and hurt everyone's business. On the other hand, if a prospect chooses to wait a week or more to register, we encourage that decision. We tell them that the business will be just as good next week as it is today. There is no rush. The difference in this situation is that then prospects make their decision - it was not imposed on them. There is a remarkable difference! Furthermore, I do not believe that prospects need to have exposure to past litigations revealed to them by an IBO. Again, that infers that the possibility exists that the business is unethical. Unethical individuals bring about litigations - not the business itself. Finally, there is no reason for an IBO to provide prospects with financial records. Every IBO will succeed or fail based on his/her effort. That information would only cause unecessary problems. That's not a "need to know" type of disclosure anyway. Other businesses and professions are not required to make such disclosures - why even consider that for small home-based businesses? It is my opinion that the FTC is presently considering the imposition of regulation that would be unfair to my business and can cause undue hardship. I realize that the FTC's general objectives are good, but there must be a less burdensome way to achieve the goals. Sincerely, Iris Michelini (Quixtar-iTeamUSA)