| Comment Number: | 522418-12569 |
| Received: | 7/17/2006 10:55:01 PM |
| Organization: | Quixtar |
| Commenter: | Fred Harlan |
| State: | IL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Gentlemen – Concerning the FTC Proposed “Trade Regulation Rule on Business Opportunities.” My wife and I have been IBO’s in the Quixtar organization for about 4 years. Our current goal is 2500 PV level (about $6000 of business going through our line). We are using the Quixtar system to enhance our retirement earnings, as well as the ‘nest egg.’ The system fits into our lifestyle by encouraging us to meet more people, build relationships with them, and determine whether or not there are areas in their lives that they would like to improve with our assistance. We have seen several benefits in the four years that we have been active – We have met many new people. We have traveled to several states and to Canada – places that we would not have thought of visiting except for our business. We are much more adventurous now than before, whether in traveling or in meeting new people or in going into new situations. When we registered, our sponsors made sure that we realized that we were not entering a “get rich quick” scheme. They provided a brochure that showed numbers, ideas, and concepts that we could review at our own pace. We provide that same type of information to prospects to whom we show the business. When we register new IBO’s, we sign them up with a registration fee of about $65, and we ask them to buy about $250 of products each month (actually 100 PV, but it costs about $250). The products are guaranteed. There are Partner Store products which have a manufacturer’s guarantee, and there are Quixtar products which a 100% policy for ANY reason. Although I have 5 major concerns with the proposed rules, two of them are related to the financial claims. I would have to make a different disclosure for each financial claim, and I would have to substantiate with documents. I do not make exaggerated claims of income during a presentation because I do not present this system as a “get rich quick” plan. We also point out the average Monthly gross income for active IBO’s. I feel that pointing out such an income claim should be sufficient and that nothing more should be required. I also feel that disclosing our income is inappropriate since we do not make income claims, but we only say that at different levels, different income levels are attainable, depending upon the organization of the business. We tell prospects that their income level would depend upon their own activity. I hope that you find this information useful. Fred & Doris Harlan West Chicago, IL