|Received:||7/17/2006 1:57:08 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I'm writing as a Quixtar IBO to support some of the proposed rules and also address concerns with others. First off, I need to express the broad satisfaction with the experiences I've had. I have an opportunity in my hands to create a lifestyle for my family that quite frankly isn’t possible in an employee setting or even as a traditional business owner. The corporation that backs me is 2nd to none, leading the industry in cutting edge products, world class customer service, and an award winning warehouse and distribution system. When I first got started, I was trained coached and encourage right from the get go. I was fully aware the income potential as well as the option to not make any income at all. That my business success would be up to me and my willingness to learn, impressed me. I'm glad my sponsoring IBO didn't put up a smoke screen and lead me to believe that I could have success with no work. I was told before I ever signed up that this would take consistent and persistent work and required a desire to be trained and coached. My relationships with family and friends, and my performance at my 9-5 job all excel because of the mentorship and experiences I've had as a Quixtar IBO. I do have some concerns regarding some of the new proposed rules. For example, the 7 day waiting period is foolishness. We're taking on a business not getting a gun permit! When I was registered, I took the time I needed to research the people and the company and got started. I never let an IBO join my team until they have all their questions answered. With Quixtar, an IBO who decided down the road, the program is not for him/her, can get their money refunded to them. Quixtar already provides a reasonable cancellation policy. Requiring new IBO's to wait 7 days would only slow down and harm my business as well as hinder the grown of new IBO's I bring on. Next, the requirement to provide references is unnecessary. When IBO's on my team are sponsoring a new person, they will introduce that person to me to get me perspective and get their questions answered in a business meeting and atmosphere. I wouldn't want my personal address, and home phone #'s disclosed to every person looking at the opportunity. Additionally, no one wants to be called during dinnertime for example regarding new prospects questions (privacy, family time). There is already a time and place set up to get a new person all the references they need, at a scheduled business meeting. Regarding the requirement to provide a litigation list, The proposal doesn't adequately cover what a "seller" is, meaning that IBOs may have to list all litigation involving Quixtar itself as well as the entire IBO force across the country. This would also not be limited to cases found against the seller but even filed cases with no merit. (Which happens all the time). Regarding disclosures of income/ substantiation, I provide the FTC document SA 4400 to everyone I present the business plan to. This is an illustration of income that can be earned if they work hard. They have no need to know my exact income and even more importantly have access to my personal info. To be required to provide disclosures of anyone you are discussing regarding success stories is redundant. The SA -4400 is more than enough to explain that your income in Quixtar is based on you, no one else. The company is solid, and has never been late on paying out my monthly bonus, ever. So the integrity of Quixtar itself is exemplary. Being a Quixtar business owner enables me to create income for me and my family and gives me the pride that I'm the owner. In addition to income generated by millions of IBO's, this business also strengthens our national economy and provides millions of tax dollars to state and federal governments from the commerce we create. Why in the greatest country in the world would the FTC create rules to stifle growth of an organization that has leaded the way in being ethical, moral and legal in its entire doings?