| Comment Number: | 522418-12742 |
| Received: | 7/17/2006 11:54:09 PM |
| Organization: | Quixtar / IBO Association |
| Commenter: | Paul Singer |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I have been a Quixtar IBO for over almost six years. In that time friends and family have at times tried, by presenting gossip from the internet and by asking question that cover information covered in many of your current proposals, to deter me from the pursuing my efforts. What I have found through years of research, personal experience and reflection is that, like any endeavourer, those who have not shared in the joys and sorrows, struggles and victories of that effort can not fully understand or appreciate the gains that have been made. We are in the business of providing hope to people who feel they have none. I and all of the poepl I have observed, make every effort to let propective business owners know the risks and reasonable outcomes that they are facing. We make it clear that they are entering into a business, that it will not be easy, that they may invest more than they take out and that they are most likely going to face fears and doubts they have never had to deal with before. We let them know they have 30 days to change their minds and most likely can get all of their start up cost reimbursed. Since we ar ein a business of hope, and it is such a fragile commodity, a seven day waiting period could easily deprive them of an opportunity to see success in action and cause them to loose hope. It places a huge burden on the IBO to double their work load and increase paper work and record keeping. Most IBO’s are not experienced business people and a preponderance of regulations would scare prospects away and deter activity, resulting in more failed business start up, the exact situation these proposals are designed to prevent. The concept of providing references is a good idea done poorly. As a home based person to person, combined with the rules of conduct as it relates to the line of sponsorship, such a proposal would virtually eliminate the possibility of expanding your business overlarge geographic regions where a new partenr could be the first for many mile around. This goes against the principles of free enterprise and promotes territorial ownership and restricts free trade. The requirement to provide a litigation list without being able to reasonable include all of the details and outcomes and circumstances of each case would verge on liable and subject the providing IBO to lawsuits for misrepresentation. Much to broad. The current income disclosures are already misleading in terms of realistic potential in that they understate what is typical of an IBO’s income. There are to many variables to go into specifics of every example given, and again puts a burden on the IBO to have to have more detailed information that a small business owner with a business plan would need to secure a loan from a bank. In summary. Quixtar IBO’s have built their business on the basic principle that honesty, sincerity, doing the right thing and hard work awill allow them to build a successful business. The fact that other choice to use other means that wold require these regulation puts an unfair burden on honest people.