Business Opportunity Rule #522418-12679

Submission Number:
Stanley Robinson
Initiative Name:
Business Opportunity Rule
My wife and I have been affiliated with Quixtar since its inception in 1999. It has provided us with extra income to help with bills and debts and will enable my wife the flexibility to spend more time with our daughter. I am excited about the FTC's efforts to protect individuals from deceptive practices by individuals and companies within the direct selling industry. However, several of the proposed regulations seem to be unnecessarily restrictive and burdensome to those companies and independent business owners (IBOs) who already provide a substantial amount of information to prospects and provide buy back guarantees on both products and start-up materials. The provision that business owners must provide references to prospects is one example. I do not want prospects of other IBOs calling me as it would be time consuming and confusing for all involved. Meetings are available where prospects can meet IBOs in person, ask questions and take as much time as they would like to evaluate the business opportunity. The provision that IBOs would need to provide earnings disclosures is redundant as Quixtar literature provides independently verified survey information on IBO income at various levels. The same logic applies to the financial substantiation requirement and I view this as an additional invasion of privacy. We are not claiming that prospects will have our lifestyle by building the business, but that they will earn the incomes as represented in the Marketing Plan as they qualify for various bonuses. Thank you for your consideration of these concerns. Sincerely, Stanley H. Robinson, Jr