Comment Number: 522418-10813
Received: 7/16/2006 10:48:24 PM
Organization: Quixtar--Merris/Schaeffer Team
Commenter: Art Locklear
State: NC
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I've been a Quixtar IBO for almost 8 years. Mine and my wife's experiences have been totally positive and ethical. We believe that the key for a good organization are the people that lead it. Thus, I think that all of these proposed rules should be very well thought out before enacted. Most importantly, they should be decided in part by actual, successful busines owners! We have reached the goal of Eagle in our business, which is stepping stone to Platinum. Our next goal is to reach Platinum and ultimately become Crown Ambassadors. Therefore, we understand that we own a real business and have committed to it long-term. When we registered, we received all information necessary to make an informed decision, and we treat our prospects with the same respect. Our prospects understand that the Quixtar business opportunity is not a "get rich quick" plan, that hard work is required, and that there are no guarantees of success. We actually tell them this! We recommend to our prospect that they invest approximately $250 to get started right: $150 of product and registration, and $100 for business support material (starter pack). How would your independent business be affected if prospects had to wait seven days before registering? No benefit. This is a people business, and requires personal relationship. Thus, a 7-day rule would not benefit anything, but would negatively impact all good direct selling organizations. This great burden would make direct sales much less attractive, and would hugely impact the profitability of our business. How would it affect the value of the Quixtar opportunity to your prospects if, after registering, they in turn had to wait seven days or more before they could register their friends and family? Would this affect their ability to earn income with their Quixtar businesses? Of course, all of the above! How would it affect you if you were required to provide a list of local IBOs for your prospects to contact before they decide to register? This is the purpose for them coming to the Open meeting. Is there a risk that your prospect might register with one of the references instead of you? Yes...definitely, and this would not be fair! How do you feel about a rule requiring you to let other IBOs give your name, address, and phone number to their prospects? Would that violate your privacy? Yes. Not fair. Do your prospects usually meet other IBOs in your group when they register? Yes...always! Explain how this works and how a prospect or a new IBO can meet other IBOs and learn about their experiences. At the Open meetings and several other events. The disclosure document would require a list of all litigation involving the seller, its key personnel, and its representatives that deal with "misrepresentation, fraud, securities law violations, or unfair or deceptive practices with the past 10 years." Would the following pose a problem for you? Yes...litigatiion is not necessarily truth. It can be a lot of lies. The requirement for specific earnings disclosures: What disclosures and explanations about the income potential of a Quixtar business do you share with prospects today (such as the average monthly gross income, SA-4400, etc.)? The SA-4400 more than adequately covers concerns about the income potential.