Comment Number: 522418-12328
Received: 7/17/2006 8:34:22 PM
Organization: Quixtar
Commenter: Lisa Varela
State: CA
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

I have been an IBO for 18 years now and love this business. This business has provided not only financial opportunities that my family would have never otherwise had, but has given us a chance to live the American dream that we all hear about when coming to the United States. The corporation has also provided me with a safe, ethical, and moral opportunity that I can share with others. When I first started the business I was given plenty of reliable information to make a decision. This information is still available today and I provide not only credible sources, but real people for my prospects to meet. I also inform my prospects that this is not a "get rich quick" scam. They have to work hard, but will get help from the BWW team so that they are not alone! And because our business is based on word-of-mouth, I want to always foster a positive environment and experience for my prospects. So if a prospect registers and for ANY reason is unhappy, they can get back 100% of whatever they return from their registration (product pack, BWW starter kit, and all IBO registration fees) - $240 total. Therefore, I see no value in requiring a 7-day waiting period. Imposing this waiting period would seriously hinder our ability to build an organization and would have a negative impact on the profitability of a new organization. A prospect who is interested in pursuing the opportunity, will typically register within 24-48 hours. They will immediately want to gain support from their friends and family. Within a few days, I've had a prospect register and have 6 other friends and family register with them. In a very short amount of time, they have been profitable by changing their buying habits and have been able to expand their business quickly and effectively. The 7-day rule would seriously hinder this fast growth, and without momentum, the business does not grow. I do not agree with the rule to provide references as it is stated. Providing the name and numbers of IBOs in the area is a violation of each individuals privacy. Additionally, every IBO should be able to supply credible references, not just anyone in the area. I'm not sure who the local IBOs are or what they have done with the business or even how ethical they are. I'd like to think that everyone is ethical, but another IBO may be conniving and "steal" my prospect. Besides, today, without your written rule, ALL of my prospects meet my team, which is the team they will be working with. They have an opportunity every Tuesday and Friday to meet credible references who can answer their questions directly. But I will only expose my prospects to my references! Every industry does this. Ask a vendor for references and they'll give you the references who have already agreed to be a reference. When you interview for a job, the same thing happens. In the job situation, if you give a negative reference to someone, you could be sued for hindering someone's ability to make money. This opportunity should be treated the same way. The litigation list should not be required. I don't know how any other IBO has conducted their business and I should not be responsible for nor affected by the poor choices they make. A litigation list involving the seller would include all these IBOs. I have total faith in Quixtar as an organization and know they stand for all that is true and ethical. The litigation list does nothing for a prospect except confuse them. Currently, I present the FTC approved IBO plan which states the current "average IBO makes $115 per month". I believe this is disclosure enough and gives what the potential is for the individual as well as what the average person does. No more should be required. It is ridiculous to provide financial substatiation for an prospect. No business opportunity is able to do that today in traditional business. We provide examples in the form of people we work with. In all, I do not agree with these rules. Regards, Lisa