|Received:||7/17/2006 11:58:19 PM|
|Organization:||Quixtar-affiliated Independent Business Owner (IBO)|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:My wife, Audrey, and I have been IBOs since 1977. We began our business in order to supplement our job income. We were shown the marketing plan by a neighbor and friend whom we knew to be straight forward and honest and highly respected in our community. The oral presentation and printed material clearly showed us that the relationship between customer purchases and IBO costs were resonable and would produce a profit with which we could reach our goals. We make similar presentations to the person we sponsor, and urge that they make similar presentations. It appeared reasonable to us that we could earn, with hard work during non-job hours, an additional four hundred dollars ($400) per month. As time passed we were able to earn enough to assist with the education of our three sons, and later enough to permit us to leave our jobs. The requirement of a seven-day waiting period: Such a period is unreasonable. It would dalay start -up, the commence of cash flow, and may even lead to a loss of momentum and a loss of interest in beginning a business. The requirement to provide references: We introduce applicants to both new and experienced IBOs. This ia practice. No benefit could be derived from making it a requirement. The requirement to provide a "litigation list". There would be no benefit for the applicant. Would an applicant to Harvard University's undergraduat school benefit at all from a review of Harvard University's litigation history? No. Earnings Disclosures: We make no earnings disclosures. We show the figures in the marketing plan, the 6-4-2. Financial Substantiation:: I provide no information about our personal income from our Quixtar business. The FTC should not require that I provide the applicant with my financial records. We should be required to say to the appplicant tht if he or she follows the plan,, he or she will earn the money shown in the plan.