| Comment Number: | 522418-12084 |
| Received: | 7/17/2006 6:16:12 PM |
| Organization: | |
| Commenter: | Kaushik Bhanderi |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
My wife and I are Quixtar IBOs for last 12 years and we have achieved our initial goal of becoming a Platinum IBO. We are in process of achieving our next goal which is Emerald IBO. In addition to making extra income, our lives have been impacted in many ways – some of the benefits include learning people skills, becoming a better person ( husband and father ), gaining a sense of accomplishment. When I got started, I received enough information ( including the average income of an active IBO ) to make an informed decision. I provide the same kind of information to my prospects. I always make it clear to my prospects that this business is not a “get rich quick” scheme and work is required ( just like any other business ). A typical startup cost for this business is about $200 that includes registration and optional product pack. If the IBO decides to discontinue, he/she gets the full amount back from Quixtar Corporation. I want to make following comments regarding the proposed rule: 1. The requirement of a seven-day waiting period: Since there is a money back guarantee, I don’t see any benefits in waiting for seven days before a prospect gets started. Besides, in my experiences, IBOs have gotten better results in first few days of seeing the plan of getting other people started because of the excitement and fresh knowledge. If every prospect has to wait for 7 days, it will prolong the overall process unnecessarily. I may not have gotten started if this rule was in place ( and would have missed out on this wonderful opportunity ! ) 2. The requirement to provide references - I strongly disagree with this rule. First of all, I would have to spend extra time and energy in maintaining the list of local IBOs. Also this would also risk my prospect being “stolen” by someone on the list if my prospect contacts them. This would not be fair! Besides, I would not want anyone to give out my information to the prospects without my permission. Doing so would directly violate my privacy. Also since we have enough associations/meetings that a prospect had enough opportunities of meeting other IBOs/ prospects and talk to them, this rule is absolutely not necessary. I would certainly have not gotten started if this rule was in place. 3. The requirement to provide a “litigation list”: I believe that providing the litigation list to prospects will confuse them. It would not have helped me at all if someone had provided this list to me. Since this list may also include cases with no merit/credibility, there is no reason to spend time and energy on this. Also just because one IBO committed fraudulent activity, does not mean that everyone else does not follow proper business ethics. 4. The requirement for specific earnings disclosures: When I talk to a prospect, I always share with them a document that mentions the average income of an active IBO ( SA-4400 ). Also I emphasize that there are no guarantees and the numbers used in the business plan is just a guideline. It would make my presentations unnecessarily long and complicated if I had to make a separate disclosure for every example that I use. 5. The requirement for financial substantiation: When I talk to the prospects, I always tell them that their income strictly depends on their performance and the Quixtar business plan. I believe that information about my income ( from all sources ) is personal information and I don’t need to share it with anyone. The money I make has no bearing on anyone’s success in this business. When I got started, it would not have helped at all if someone showed a bonus check to me since I knew that my income always depends on my performance. In conclusion, I hope that you will consider my comments before finalizing the rule. Thank You.