| Comment Number: | 522418-10785 |
| Received: | 7/16/2006 10:29:52 PM |
| Organization: | Quixtar |
| Commenter: | Kayleen Clute |
| State: | MD |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
RE: Business Responsiblity rules I have been a Quixtar IBO for 6+ years. The business has not been extremely financially lucrative, as I have not pursued it in a manner necessary to make it my sole income. I have found Quixtar beneficial in its development of many nutritional products that myself and friends use regularly. It has enhanced my experience in holistic medicine, which has enriched my practice with patients as a pediatric nurse practitioner. I have concerns about some of the proposed rule changes: The 7 day waiting period doesn’t make sense as the registration should be with a money back guarantee for an appropriate period of time. It would make better sense to require a refund upon request such as Quixtar does with registrations. No Listing of references (10): would be like giving the prospect names of competitors. They can already come to a meeting and meet people who are in the business network. I think the disclosure of financial is met through simple legal jargon as part of the required handout for anyone becoming an business owner…are needed, require a simple, standard, easily understood disclosure such as our, "average monthly gross income for 'active' IBOs." I feel it is inappropriate to required me to provide prospects with personal financial documents to "substantiate"any income claim. In my present business situation, that would be suicide. As I mentioned, I have not pursued my business diligently. That does not mean that I should need to give someone my income documents when I do start to pursue more consistently. I would act as a professional and being made to disclose my income to anyone who asks would be in violation of my privacy. I think the financial income disclosure as discussed above should be enough. Small business people can be struggling in many arenas. It is best not to legislate moral disclosure. IBOs 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. Thank-you for taking the time to read my comments. Most Sincerely, Kayleen Weinman Clute, MSN, CRNP Pediatric medicine Independent Business Owner, E-Finity, Quixtar