| Comment Number: | 522418-10597 |
| Received: | 7/16/2006 6:36:31 PM |
| Organization: | Ecom Promotions Inc (Quixtar IBO) |
| Commenter: | Christopher Miller |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been a Quixtar IBO since 2000. I have achieved the Gold producer level which is the top of the Performance bonus scale for 3 months out of the corporate year. When my wife and I began our business it became clear that the Quixtar business was a group of people that under sold but over delivered. We could easily see that this was not a get rich quick scheme but with time and hard work we could grow our business to any level that we were willing to work for. When we register a new prospect I encourage them not only to take time but to seek information from informed sources. I also encourage them to meet the local team to be sure that they are comfortable with the people that they are going to work with. Fortunately the initial registration is $110-170 dollars with a 180 day satisfaction guarantee allowing even unsure prospects ample time with no risk of loss. It has no value to have uniformed prospects join the business only to find later that it was not what they expected. I am very excited to make the Quixtar business my full time profession. After reviewing the proposed action I could not help but see that the burden would be on the companies that are already engaged in honest practices. The difficulty in enforcing this proposal would create tremendous difficulties while doing little to accomplish the stated goal. Although the idea of making it difficult for fraudulant companies to do business is very attractive, we should not forget that all business has risk and it is the individuals responsibility to assess that risk. 1. To require a 7 day waiting period for companies that do not offer a return policy, not for companies that already have this protection in place for prospects. This seems prudent. Also for companies that have a large capital investment as long as this is required when people purchase other business’s 2. To require references, would infringe on people's right to have privacy in the ownership of their business while having little impact on getting to talk to people actively building a Quixtar business. This is why we encourage prospects to attend local team meetings to meet the people that are actively building a business. 3. As a company gets larger it will always become a target for people that will see this as an opportunity to lawsuit. Because anyone can file a suit this would imply wrong doing by the company when no fault has been committed. This would certainly skew the image of established companies. This information is already a matter of public record. 4. Make income disclosure based on averages which the Quixtar business has always done. It is clearly stated during registration and must be accepted that the prospect understands this before registration. To go beyond this would not make the prospect any more informed. 5. To disclose personal income statements would be a very unreasonable requirement. When someone joins our Quixtar business I am not offering to sell them my business but to help them start, from scratch, their own business. A business that has no guarantee of success. Like any other business it is up to the individual to build and work their business to make it a success. My financial information will not give any evidence that they will succeed and may possibly give them an inaccurate potential of income based on their commitment level.