|Received:||7/17/2006 11:12:26 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I am an Independent Business Owner (IBO) affiliated with Quixtar. I became an IBO in 1993 when it was primarily a catalog based business. We registered as IBOs primarily to purchase products at a discount but are now actively building our business. We were told in every presentation that this was not a “get rich quick” business and that to be successful required a four letter word - “WORK”. When we registered we received information on not only the potential of the business but also information on the “average” earnings of all active IBOs. What we’ve learned since joining the business is that everyone we’ve come in contact with conducts business in a highly professional and ethical manner based on Faith, Family and Freedom values. The positive aspect of the business is that it helps to build character and relationships in addition to providing an opportunity to develop to whatever financial level you wish - if you do the WORK! When we talk to people about the business opportunity, we stress that it requires WORK and that it is not a “get rich quick” business but that the opportunity is there to make whatever income is desired if you follow the proven development program. The literature we utilize and the presentations we show all stress that there are no guarantees – you have to do the WORK! We share information on the average monthly gross income through “The Independent Business Ownership Plan” (SA-4400). We fully explain the products, the Quixtar web site and its affiliated partner stores. The presentation fully explains the income opportunities (including both the sales income as well as the networking income opportunities). The registration fee to become an IBO affiliated with Quixtar is listed on the site. Optional products purchased by the IBO carry a 100% return policy. Optional business development program materials (which teach the concepts and skills necessary to develop a successful business) are also covered by a refund policy. We provide a mentoring program (at no cost for our time or services) to assist the new IBO in developing a successful business. The program is voluntary on the part of the IBO, but it is there for the asking. Our business would be severally limited if prospects had to wait 7 days before registering. We build a relationship over time with each prospect (with a corresponding expenditure of our time, effort and travel expenses). A 7 day waiting period would not give the prospect anymore benefits than we presently offer and could, in fact, negatively effect the propect’s ability to earn income for that month. Once registered, the prospect would be forced to apply the waiting period to others he might be talking to with a corresponding potential negative impact on his ability to increase his income in any one month. We build our business by developing our own contacts. Requiring an IBO to provide a list of local IBOs would be like requiring a salesperson to give the prospect a listing of all his competitors. I have spent my own resources in developing a particular prospect – why should I be forced to expose him to other IBOs who do not know him and might seek to convert him to their business? Requiring separate disclosures for each income level would needlessly confuse the issue. The issue being that it is POTENTIAL INCOME – it will not occur if the prospect does not do the WORK. I do not tell prospects what I’m making. It doesn’t matter. If they have a desire for a certain level of income and are willing to WORK and that WORK is more than the effort I’m making – then they will make more than I! That’s what I stress. Listing “all litigation” whether with merit or not is severely misleading. You would not apply this concept to other employers (retailers, information companies, fast food restaurants, the media, etc.). To make an informed decision, the prospect can obtain relevant information from the Better Business Bureau, Dun and Bradstreet and other readily available resources.