|Received:||7/16/2006 9:13:01 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My name is Vinay Shankar. My wife, Mamatha & I are Independent Business Owners (IBO) affiliated with Quixtar, part of the Alticor group of companies. My wife & I are both well educated professionals with Masters degrees working in Corporate America. We got involved in the quixtar business when we realized that we can NEVER achieve our financial goals and dreams working for somebody else. After being laid off at the same time a few years back, we realized the need to get involved in a business opportunity that allowed us to work together. I checked out several opportunities and was always put off by the cost to get involved. When a friend of mine introduced me to the Quixtar business model, I checked it out. I liked the integrity and calibre of professionals I met at my first seminar. I was given literature material, audio CDs and a video which provided me sufficient information to make a decision. I also got a chance to meet my friend and his mentor 2 days later and get my questions answered in great detail. I also went to a get-together a day later where I could interact with some local IBOs from the same team and get to hear their experiences after joining the business. A day later, we got registered because we liked the opportunity and the people we were getting involved with. We are excited about the future the business holds for us and people in our organization. My wife and I currently work for major companies but believe we can achieve our financial goals through the quixtar business opportunity. I would like to comment against the proposed rule as this: The requirement of a seven-day waiting period: When we got involved, within 2 days, we were able to make a decision to join. 2 days later, we introduced it a good friend and he joined after 2 days. So within a week, we joined and started our organization! Had we been asked to wait 7 days, there is no guarantee our excitement to join would have remained. Secondly, there is no gurantee we would have been able to register our friend. Imagine if you were a car salesman and you just showed a customer a car and you wanted to close the deal but were told you had to wait 7 days! With quixtar, there is a 180-day money back guarantee. If somebody decides not to continue, they can get their money back within a 180-day period. That is the ultimate guarantee. The requirement to provide references: The business is based on your hard work & effort. If I get a prospect sufficiently interested in the business opportunity and then had to provide references, they could join under somebody else negating my efforts. We have seminars, get-togethers, one-on-one meetings where a prospect gets enough information to make a decision. But the above rule does not guarantee anymore that my prospect will join under me. This is not fair to my efforts at all. The requirement to provide a "litigation list": Can you imagine if any company had to provide any candidate they interview a list of all litigations in the last 10 years? They would scare candidates off and have a hard time recruiting anybody. The requirement for specific earnings disclosures: Currently we provide a FTC approved document, SA4400 which lists the compensation plan and dispays that the average monthly gross income is $115. If I had to make a seperate disclosure for every example I used about myself or anybody successful in the business, it would require more time and take the emotion out of the whole business opportunity which attracts people. The requirement for financial substantiation: The marketing plan is what a prospect can achieve. We don't make false claims about how much money we make. We let prospects know that this is not a get rich quick scheme and hard work & effort is involved. I urge all of you consider the voice of genuine and legitimate business owners and ensure that the above rule does not hurt our ability to attract prospective IBOs and build a tremendous future. Thank you.