|Received:||7/17/2006 9:24:33 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I, Paras Shah, am an active IBO affiliated with Quixtar Corporation. I would like to give some feedback to FTC from my personal experience of being affiliated with Quixtar in regard with FTC’s recent proposal. I really appreciate the FTC’s initiative towards combating fraud and bogus practices. I have been IBO from more than 2 years now with Quixtar. The business opportunity has given me a financial benefit in addition to my personal growth as a business owner. An income from this business has created a security in my personal finance. When I was introduced to this opportunity, undoubtedly was given a lot of information including company facts and figures and web-site references. And I follow the same process in introducing this opportunity to people and helping them to start their own business. I use material like SA-4400 and website like www.quixtarfacts.com to make other person informed with facts. As I personally share this opportunity, some important things I focus are opportunity being performance based reward system and requires certain amount of work to create the shown income. Also, while I register any other individual with Quixtar, I make sure to inform that they can get the registration money back if they decide to leave in agreement shown time period. In regard with the requirement of a seven-day waiting period of proposal, I would like to say that in certain situations this might hinder the growth of my business. I would rather allow the prospect’s comfort level decide the waiting time period. Different individuals have different education and professional background and hence do have different pace of understating the potential of business opportunity. In my business, momentum of my organization has been very vital factor and which might be affected by the seven-day wait period. And also IBOs can also be unable to reach to certain goals. In regard with the requirement of providing reference list of other IBOs might confuse the prospect. Surely, as a prospect gets a chance to meet other IBOs, but at the same time he/she might not comprehend the feedback of different personalities at different level of success. From my experience, any prospect being helped (in terms of sharing opportunity and leading him to next level)by one IBO in initial phase can be more effective as far as the IBO do share all facts and figures. And it is very difficult to share personal information of my business with and keep track of other local IBOs as every individual have their own personalities and style of building business. We, the organization of IBOs, build our business in a unique way. Also, we do give every IBO access to IBOAI which is a legal entity. Surely, we do take care of prospect meeting other IBOs in different associations organized by BWW. In regard with the requirement for specific earnings disclosures and financial substantiations, I would like to say that I share all the income levels and type of incomes available from Quixtar business opportunity and SA-4400 is the best literature to explain the prospect the potential of the opportunity. As the proposal mentions about disclosing personal income, I personally feel that it would be not effective in every case. For example, an IBO who has worked on this opportunity on 3 months with previous business background might yield very different results from another IBO who has not any previous business background and taking some time to learn. So, my income disclosure might make the prospect having wrong expectations as he/she is not aware of the amount and the style of work I have done. Every time, earnings in this business changes and knowing earnings of one IBO at given point of time can not do justice to show the potential of the opportunity. So, I would not feel comfortable to share my personal income information with the prospect not because I don’t want them to be aware of, but it doesn’t fulfill the purpose of explaining the opportunity potential.