| Comment Number: | 522418-10504 |
| Received: | 7/16/2006 3:51:01 PM |
| Organization: | Quixtar |
| Commenter: | Charles Eilers |
| State: | MO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Allow me to thank the FTC for its efforts in securing ethical and honest practice in the direct sales industry. My five years with Quixtar has provided me with a decent secondary income. Everything required to reach higher levels has been provided to me. The principles that Quixtar stands behind are fair, honest, ethical,and seek the best for everyone involved. By providing an opportunity to utillize the free enterprise system, the company provides the ability to not only increase your lifestyle but educate yourself, and others to change their lives for the better. The recent proposals to the change in business practices for the direct selling association may create a crippling effect to many businesses. Thank you for reading the following. -------------------------------------------------------------------------------------- Prospects would have to wait seven days after receiving disclosures before they could register. ----Prospects have access to numerous resources to practice their due diligence. This would only delay their success. Please eliminate the waiting period, at least for opportunities like Quixtar where a prospect can get their money back if not satisfied. ------------------------------------------------------------------------------------- Required to give every prospect a list of "references" – the names, addresses, and phone numbers of 10 other IBOs in the area – seven days before the prospect registers. ----This opens the door to unwanted sales solicitations to these references and the providing of the list to others, which can be an invasion of privacy. Every Quixtar prospect is encouraged to talk to as many other business owners and ask as many questions as they choose at any information session they attend. In fact, we introduce them to our associates. This requirement would infringe on the privacy of every IBO whose name, address, and phone number was provided to prospects. It would also penalize the sponsor, who would be required to give his prospect contact information for 10 other IBOs, any of whom might be happy to register the prospect themselves. Please eliminate the requirement to provide 10 references. --------------------------------------------------------------------------------------- Have to 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 – regardless of whether or not the accusation was true. ----Among other problems, this requirement would open up Quixtar and other legitimate companies to false accusations. Meanwhile, dishonest companies would simply ignore the rule. Please eliminate the requirement to disclose past litigation. --------------------------------------------------------------------------------------- Would have to 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." This by the way, is provided to prospects by Quixtar IBO's. --------------------------------------------------------------------------------------- Required to provide prospects with personal financial documents to back up ("substantiate") any income claim. ----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. Let me express my appreciation again to the FTC for its efforts to maintain the ethics in our industry.