|Received:||7/17/2006 10:15:59 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am Robert Reynolds, Colonel USAF (Retired) Quixtar IBO # 473579. I have been a Quixtar IBO since Nov 95. After a slow start I have a healthy growing organization with a gross of over 200K in sales a year. After 30 years in the Military, I almost duplicated my retirement in 14 months. My sponsor, a West Point Graduate, more than adequately prepared me for the AMWAY then Quixtar experience and business model. He clearly explained the business from top to bottom as well as the approximate monthly and yearly cost of running the business. I understood it would take work without guarantee of a specific financial reward. With start up cost ranging from $55 to approximately $250 dollars, I elected to invest in the full getting started right package including sample products. It was never presented as a get rich quick business. I benefited from the Britt World Wide organization and continue to prosper in this unique business. Because of the strong emphasis on Family values, loyalty to country and support of our Government, and Free Enterprise, I believe Quixtar alone should get a government stamp of approval for all Active Duty, AFRES, ANG, and retirees with strong government support through the SBA for business start up support. Particularly in the transition from active duty to retirement. Additional DoD legal language encouraging business development and growth on active duty should be encouraged. I have read you entire package and offer the following comments. 1. Problem 1. I do not believe a waiting period is necessary for the business that offer a 100% money back guarantee as Quixtar does. 2. Problem 2. I do not believe I should be required to present 10 references to a new prospect. This is still a competitive business and it would introduce the opportunity for a competitor organization to benefit from my work without compensating me if my prospect were to join their organization with my use of their name for a reference. 3.Problem 3. Because of the competitive nature of our business, providing a prospect a list of all lawsuits, arbitrations, and other legal claims for the past 10 years would encourage a competitor to file baseless, even frivolous lawsuits. I would be unprotected and in fact vulnerable to illicit business practices without the financial means to defend myself. It would seem to encourage frivolous lawsuits meanwhile; dishonest companies would ignore the rule. Besides, I believe in the law, if a lawsuit does occur, I believe the judicial system would correctly settle the issue. What does a past legal action bear on future business but to ensure best future business practices? Once again, this would appear to bear more on companies that do not offer a 100% refund for start up expenses. 4. Problem 4. Disclosures of income claims. If disclosures are required, require a simple, standard, easily understood disclosure such as an average monthly gross income for ACTIVE IBOs only. The current disclosure is very misleading since it includes both active and inactive IBOs. It skews the data to a lower average income for current active IBOs 5. Problem 5. The requirement to provide prospects with personal financial documents to back up income claims is intrusive to my personal privacy. However, we should not be exempt from standard disclosures when required by the FTC and similar agencies in an investigation. Once again, it is difficult to legislate integrity in business and I support your general objective and efforts to to discourage illegal even predatory business activity. I belive there are many legal means in place to prosecute illegal business activity without creating represive business rules represented in the 5 problem areas I have highlighted. I volunteer to be interviewed with respect to my experiences with Quixtar if it will help you in your actions for this industry.