Business Opportunity Rule #522418-12682

Submission Number:
Nancy Briski
Initiative Name:
Business Opportunity Rule
To Whom This May Concern: My husband and I own our own distibution business by which we have a contract with Quixtar. We applaud the FTC regarding its wishes to ensure that every prospect considering a business opportrunity such as ours has all of the information needed to make an educated decision and support reasonable and responsible rules to help manage the expectations of these prospects. We hold our business to a certain standard with honesty being the foundation to gain trust and respect to assist others with their achieving their goals. While reviewing the proposal, we wanted to give feedback on 5 specific areas that we feel may hinder our busines and wanted to offer an alternative for each. Problem 1: Prospects would have to wait seven days after receiving disclosures before they could register. Solution: Eliminate the waiting period. Opportunities such as that through Quixtar offer the prospect a way to get their money back if not satisfied. Problem 2: You would be required to give every prospect a list of references:-the names, addresses, and phone numbers of 10 other IBOs in the area-seven days before the prospect registers. Solution: Eliminate the requirement to provide 10 references. This would infringe on the privacy on independent business owners. We may also lose customers as well as other potential prospects because the other 10 references may want to register that person themselves. Problem 3: You would have to give every prospect a list of all lawsuits, arbitrations, and other legal claims for the past 10 years involving Quixtar and its IBOs where the plaintiff alleged fraud, misrepresentation, or unfair trade practices- regardless of whether or not the accusation was true. Solution: Eliminate the requirement to disclose past litigation. This requirement would open up Quixtar and other legitimate companies to false accusations. It would be a free-for-all for dishonest people to hurt our business. Problem 4: You would have to make a different disclosure for every income claim. Solution: If disclosures are needed, require a simple, standard, easily understood disclosure such as "average monthly gross income for 'active' IBOs..." Problem 5: You would be required to provide prospects with personal financial documents to back up ("substantiate") any income claim. Solution: IBOs should possess substantiation for any claim but should not be required to disclose it except when required by the FTC and similar state agencies is an agency investigation. Overall, we do support the general objective of the FTC to protect people from fraudulent businesses, however, we do not support it hurting legitimate businesses as outlined above. We are very satified with our relationship with Quixtar as well as our business support and education provided by World Wide Group in its efforts to assist my husband and me meet our financial goals. Thank you for your time. Sincerely, Nancy Briski