|Received:||7/17/2006 6:24:37 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
|Attachment:||522418-12105.pdf Download Adobe Reader|
Comments:Our experience with Quixtar We were given enough information in order to make an informed decision on whether to register or not and we continue to supply the same information to those whom we register. We inform them that it isn’t a get rich quick or a something for nothing plan, that there is work, effort, & energy involved in order for them to achieve any success with the business and that we don’t make any promises or guarantees of success. They gain more insight and information of the business through CDs, books, literature, workshops, seminars, and having access to their business support team. Prospects typically invest about $132.00 dollars on the initial registration. Should they decide the business isn’t for them, they can mail or fax a letter stating so to the corporation and their registration fee is refunded 100%, with them keeping the product introductory pack, which is valued at $55.00 dollars. The requirement of a 7-day waiting period: This would slow down registrations, slowing the growth of the business. By them being registered as an IBO without a waiting period, they’d have access to the team website, and the business support materials only available to IBOs. The profitability of the business would decrease due to purchases as an IBO not able to be made until after the waiting period which would inhibit their ability to earn income with their business. It would be de-motivating for a new IBO having to wait to register anyone; hence the value of the business would decrease. Once registered, we supply them with CDs, books, & other literature regarding their business, we inform them of dates for the upcoming workshops, seminars, the continuing educational program, voice-mail, and team site available to them. We assist them to set up a Ditto Delivery Profile of consumable goods of their choice, we assist with scheduling appointments for the business to be shown to others for them, and educate them on how to acquire customers. With a waiting period the prospects knowledge of the business would be largely based on what they either heard, or read on the internet of which is unsubstantiated, hear-say, slanderous, and for the most part, negative and that isn’t fair to the prospect or the IBO registering the prospect. The requirement to provide references: Individuals can’t speak for or account for the thought process or the actions of another. Who’s to say that the other IBO references have the knowledge, experience, dedication, commitment, enthusiasm, and over-all character as that of the registering IBO? The prospect might even register with one of the referenced IBO instead of the one who presented the business to them. A new IBO meets plenty of other IBOs within their perspective organization and their entire support team as soon as possible through the workshops, seminars, and even CDs. I don’t want my privacy violated by another IBO giving me as a reference and giving my personal information to someone of whom I don’t know, didn’t approve or authorize. This would also cause additional time consumption spent on the phone, through e-mail, regular mail, and possibly even in person, answering questions to prospects, which is valuable time that could be invested with those in our own business. Requirement to provide a "Litigation List": One should not be penalized by the actions of another nor does the character or a practice of one IBO define that of another. I want a prospect to view this business based on how they view me, with what they see and experience of me and my character, not from some filed cases with no merit or filed cases with merit against another IBO that deal with misrepresentation, fraud, securities law violations, or unfair or deceptive practices of which I myself wouldn’t do business with due to their lack of character and wrong practices? The requirement for specific earnings disclosures: The disclosures and explanations about the income potential of a Quixtar business we share with prospects is the SA-4400, which states the average monthly gross income along with other sufficient information. Additional information would be irrelevant. The business presentation has enough disclosures and explanations about the income potential of a Quixtar business without having to include a separate disclosure for every example used in explaining the income potential of a Quixtar business to a prospect? The requirement for financial substantiation: Having to do this would be inappropriate because our financial records are a personal matter and not open for discussion with just anybody. If asked, I might tell them how much we make, depending on the prospect and how I am asked. Regardless, I describe the impact our business has made on our life.